Quashing SC/ST Act Proceedings Based on Voluntary Compromise and Absence of Public View

The petitioners sought quashing of FIR No. 39/2022 registered under Sections 385, 387, 341, 323, 354, 467, 468, 471, 504, 506, and 34 of the IPC and various sections of the SC/ST (Prevention of Atrocities) Act.

The informant (Opposite Party No. 2), an Anganbari Sevika, alleged that Petitioner No. 1 (husband of Petitioner No. 2, a Sahayika) forcibly snatched an attendance register, demanded money, and hurled caste-based abuses.

The petitioners contended the FIR was retaliatory following their complaint against the informant's irregularities.

During the pendency of the application, the parties filed a joint interlocutory application (I.A. No. 01/2026) stating they had amicably resolved their private dispute and did not wish to pursue legal remedies.

1. Whether criminal proceedings involving offences under the SC/ST Act can be quashed on the basis of a compromise between parties.

2. Whether the allegations in the FIR satisfied the requirement of "public view" and intent to humiliate based on caste as required under the SC/ST Act.

Section 482 of the CrPC regarding the inherent powers of the High Court to quash proceedings to prevent abuse of process or secure the ends of justice.

Principles established in Ramawatar v. State of Madhya Pradesh (2022) and Ramgopal v. State of M.P. (2022), that non-heinous, private disputes under the SC/ST Act can be quashed on compromise even at post-conviction stages.

The "public view" doctrine from Swaran Singh & Ors. v. State (2008) and Karuppudayar v. State (2025).

Principle from Hitesh Verma v. State of Uttarakhand (2020) that an offence is not established under the SC/ST Act unless the intimidation is specifically intended to humiliate the victim due to their caste status.

The Court observed that the dispute was predominantly private in nature, arising from administrative friction at the Anganbari Centre, rather than caste-based animosity.

Per Karuppudayar, the Court found that the incident took place within the "four corners of the wall" and not in "public view," thereby failing to meet the statutory threshold for sections 3(1)(r) and 3(1)(s) of the SC/ST Act.

Regarding the compromise, the Court verified the physical presence of the parties and the joint affidavit, concluding the settlement was voluntary and devoid of coercion.

The Court reasoned that since the offences were non-heinous and private, continuing the prosecution would be an abuse of the court's machinery, and quashing was necessary to do complete justice.

Consequently, the High Court allowed the application and quashed FIR No. 39/2022 and all consequential proceedings.