Quashing of non-heinous criminal proceedings is permissible under inherent powers upon valid compromise between parties.

The petitioners filed a criminal miscellaneous petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), seeking to quash FIR Gola P.S. Case No. 102 of 2023 and the subsequent criminal proceedings.

During the pendency of the matter, the petitioners and the informant (Opposite Party No. 2) filed Interlocutory Application No. 6443 of 2026, supported by affidavits, stating that they had entered into a valid and binding compromise agreement.

The informant expressed a desire not to proceed with the case, noting that the petitioners had complied with all terms of the settlement.

The State raised no serious objection to the quashing in light of the private settlement.

1. Whether the High Court should exercise its inherent power to quash criminal proceedings when the parties have reached a compromise in a non-heinous, private dispute.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (formerly Section 482 Cr.P.C.), which saves the inherent power of the High Court to prevent abuse of the process of law and secure the ends of justice.

Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur and Others v. State of Gujarat and Another (2017) 9 SCC 641, which followed Gian Singh v. State of Punjab (2012) 10 SCC 303. These cases dictate that while heinous crimes (murder, rape, etc.) or offences under special statutes (Prevention of Corruption Act) cannot be quashed via compromise, cases with a "predominatingly civil flavour" or private disputes where the possibility of conviction is "remote and bleak" due to settlement should be quashed to prevent oppression.

The Court observed that the offences involved were neither heinous nor characterized by "mental depravity," but rather arose from misunderstandings between private parties.

Applying the principles from Parbatbhai Aahir, the Court reasoned that since the matter had been amicably settled, the chances of conviction were virtually non-existent.

It was determined that continuing the criminal proceeding would not serve the interest of justice but would instead cause undue hardship and prejudice to the petitioners, constituting an abuse of the legal process.

The Court allowed the petition, quashing FIR Gola P.S. Case No. 102 of 2023 and the entire criminal proceeding against the petitioners.

Interlocutory Application No. 6443 of 2026 was also disposed of accordingly.