Rape proceedings cannot be quashed under inherent jurisdiction solely on the basis of compromise.

The petitioner invoked the inherent jurisdiction of the Madhya Pradesh High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”), seeking quashing of FIR Crime No. 536/2026 registered at Police Station Kotwali Datia, District Datia, for offences under Sections 64(1) and 351(3) of the Bharatiya Nyaya Sanhita, 2023 (“BNS”) and Sections 3(1)(w)(i) and 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989

The complainant alleged that, after being introduced to the petitioner for employment, she went to his house on 19 August 2026 to cook food. On 22 August 2026, the petitioner allegedly forcibly dragged her to a bed and committed rape without her consent, thereafter threatening to kill her if she disclosed the incident. She informed her husband and subsequently lodged the FIR with the assistance of Vippu Kamariya on 23 August 2026

During the proceedings, the petitioner and the complainant filed applications seeking to place their compromise on record. The Principal Registrar verified the parties, their signatures, and the voluntary nature of the compromise, finding no threat, inducement, or coercion

The complainant supported the petitioner’s request, while the State opposed quashing of the FIR

Whether the High Court should exercise its inherent jurisdiction under Section 528 of the BNSS to quash an FIR alleging rape under Section 64(1) of the BNS solely because the accused and complainant have entered into a voluntary compromise?

Whether the precedents permitting quashing of proceedings in exceptional circumstances involving a subsequent marriage between the accused and the prosecutrix applied to the present case?

Section 528 of the BNSS preserves the High Court’s inherent power to make orders necessary to give effect to the BNSS, prevent abuse of the process of court, or secure the ends of justice

Relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303, Narinder Singh v. State of Punjab, (2014) 6 SCC 466, and State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688, the Court reiterated that inherent powers must be exercised sparingly and with circumspection; heinous and serious offences having a social impact ordinarily cannot be quashed merely on the basis of compromise

Section 64(1) of the BNS criminalises rape and protects the bodily autonomy, dignity, and sexual integrity of women; allegations of such an offence cannot ordinarily be rendered moot by a private settlement

The Court also considered Mahesh Mukund Patel v. State of U.P., 2025 SCC OnLine SC 614, and Ajay Mohan v. State of U.P., 2026 AHC 103624, but treated those decisions as fact-specific, particularly because they involved a subsequent marriage and a continuing happy matrimonial relationship between the parties

Although the compromise was verified as voluntary, the Court held that voluntariness of the settlement did not alter the nature or gravity of the allegations.

The FIR prima facie disclosed rape under Section 64(1) of the BNS, an offence involving bodily autonomy, dignity, and a wider societal interest rather than merely a private dispute

Consequently, the restrictive principles governing the exercise of Section 528 BNSS jurisdiction applied.

The Court distinguished Mahesh Mukund Patel and Ajay Mohan because the present case involved no subsequent marriage between the petitioner and the complainant and therefore lacked the exceptional factual circumstances relied upon in those cases

The seriousness of the alleged offence outweighed the parties’ subsequent willingness to compromise

It held that allegations of rape under Section 64(1) of the BNS constitute a serious and heinous offence that cannot ordinarily be compounded or quashed through a private settlement.

Accordingly, the petition was dismissed, and the interlocutory applications seeking to place the compromise on record were disposed of