Quashment of criminal proceedings for non-heinous offences is permissible upon voluntary settlement to prevent abuse of process.

The petitioner filed a criminal miscellaneous petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking to quash the entire criminal proceeding and the cognizance order dated 19.08.2014.

The case, Sonari P.S. Case No. 55 of 2014, involved allegations under Sections 406, 420, and 34 of the Indian Penal Code.

During the pendency of the proceedings, the petitioner and the informant (Opposite Party No. 2) filed Interlocutory Application No. 2600 of 2026, stating they had voluntarily settled their dispute through the intervention of well-wishers.

Both parties jointly submitted that the informant no longer wished to proceed with the case.

Whether the High Court should exercise its inherent power to quash criminal proceedings for non-compoundable offences under the IPC on the basis of a compromise between the parties.

The Court primarily applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 482 of the Cr.P.C.), regarding the inherent powers of the High Court to prevent abuse of process or secure the ends of justice.

It relied on the landmark precedent *Parbatbhai Aahir @ Parbatbhai Bhimsinhbhai Karmur and Others vs. State of Gujarat and Another (2017) 9 SCC 641*, which incorporated principles from *Gian Singh v. State of Punjab*, establishing that while heinous crimes cannot be quashed via compromise, cases with "overwhelmingly and predominatingly civil flavour" or private disputes may be quashed if the possibility of conviction is remote and continuation would cause extreme injustice.

The Court observed that the offences alleged (Sections 406 and 420 IPC) were neither heinous nor involved "mental depravity".

The Court noted that the criminal case originated from a misunderstanding that had since been amicably and voluntarily settled through a formal compromise.

Applying the filters set by the Supreme Court, the Court reasoned that because the dispute was private in nature and a settlement was reached, the chances of conviction were "remote and bleak".

Consequently, the Court determined that continuing the criminal proceeding would serve no legal purpose and would instead result in undue hardship and oppression for the petitioner.

The Court allowed the petition and quashed the entire criminal proceeding, including the cognizance order dated 19.08.2014 passed by the Judicial Magistrate 1st Class, Jamshedpur, in connection with Sonari P.S. Case No. 55 of 2014.

Interlocutory Application No. 2600 of 2026 was disposed of accordingly.