SC/ST Act proceedings may be quashed on settlement where the dispute is private and conviction is remote.

The complainant alleged that the petitioners had borrowed ₹5,00,000 from her for house construction and failed to repay it.

The resulting complaint led to a charge sheet against the petitioners for offences under Sections 323, 354, 448, 380, 504, 506 read with Section 34 of the IPC, and Sections 3(1)(r) and 3(2)(va) of the SC/ST (Prevention of Atrocities) Act, 1989, as amended in 2015.

While the case was pending before the Special Court, the parties settled their dispute through the intervention of village elders and filed affidavits stating that the settlement was voluntary and that the complainant did not wish to continue the case.

The petitioners sought quashing of the proceedings under Section 482 CrPC/Section 528 BNSS.

The Court relied on Section 482 CrPC, corresponding to Section 528 BNSS, as conferring inherent power to quash criminal proceedings, including in appropriate cases involving non-compoundable offences; that power is distinct from statutory compounding under Section 320 CrPC and must be exercised sparingly to secure the ends of justice or prevent abuse of process.

Applying Narinder Singh v. State of Punjab, (2014) 6 SCC 466, the Court noted that the High Court should consider the nature and social impact of the offences, whether the dispute is predominantly personal or civil, the likelihood of conviction, prejudice from continuing the prosecution, and the timing and circumstances of the settlement.

The Court found from the charge-sheet material that the dispute arose from financial dealings between the parties and that they had resolved it voluntarily through the intervention of village elders.

It noted that the parties were neighbours in the same village and that the complainant no longer wished to pursue the case.

Given the settlement, the Court considered the likelihood of prosecution witnesses supporting the case—and therefore of conviction—to be minimal, and concluded that continuing the proceedings would be unnecessary and an abuse of process.

It accordingly applied the principles in Narinder Singh to accept the settlement.

It quashed the entire proceedings against Accused Nos. 1 and 2 in Special Case SC/ST No. 41/2024 for the IPC and SC/ST Act offences, and allowed I.A. No. 1 of 2026.