Quashing of non-heinous criminal proceedings is permissible under BNSS Section 528 upon a valid compromise.

The Petitioner sought to quash the entire criminal proceeding arising out of Dhanbad P.S. Case No. 0326/2025, registered under Section 316(3) of the Bharatiya Nyaya Sanhita (BNS).

While the investigation was still ongoing and a charge-sheet had not yet been submitted, the Petitioner and the informant (Opposite Party No. 2) filed Interlocutory Application No. 6246 of 2026 stating they had voluntarily settled their disputes through the intervention of well-wishers to maintain peace.

Both parties jointly prayed for quashing on the grounds that the compromise rendered the chances of conviction remote and bleak.

Whether the High Court should exercise its inherent power under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 to quash an FIR based on a private compromise between the parties.

The Court primarily exercised its inherent jurisdiction under Section 528 of the BNSS, 2023 (formerly Section 482 Cr.P.C.).

It relied heavily on the principles established in Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur Others v. State of Gujarat Another (2017) 9 SCC 641, which mandates that the High Court may quash proceedings to prevent abuse of process or secure the ends of justice, provided the offense is not heinous (like murder or rape) or against society, but is rather private or civil in nature.

The Court observed that the dispute between the parties was essentially a private matter and did not fall under the category of "heinous and serious offences of mental depravity".

By applying the guidelines from the Parbatbhai Aahir case, the Court reasoned that because a complete settlement had been reached, the possibility of a successful conviction was "remote and bleak".

Consequently, the Court determined that continuing the criminal proceeding would result in "great oppression and prejudice" to the Petitioner and would constitute an abuse of the process of law.

The State also expressed no objection to the quashing in light of the compromise.

The Court ordered that the First Information Report (FIR) for Dhanbad P.S. Case No. 0326/2025, registered under Section 316(3) of the BNS and pending before the learned C.J.M., Dhanbad, be quashed and set aside.

The Criminal Miscellaneous Petition (Cr.M.P.) was allowed.