Serious firearm-based attempt-to-murder allegations cannot be quashed solely on compromise under inherent jurisdiction.

The petitioners invoked Section 528 of the BNSS seeking quashing of FIR Crime No. 82/2026 registered at Police Station Lahar, District Bhind, for offences under Sections 109(1) and 3(5) of the BNS, along with consequential proceedings, on the basis of a compromise.

The prosecution alleged that on 2 May 2026, following an earlier dispute, petitioner Mahesh Singh Chauhan fired two shots at the injured complainant, Raju Chauhan, intending to cause his death. One shot struck the complainant’s back and the other his abdomen, causing bleeding injuries; Mahesh and his co-accused thereafter fled the scene.

The complainant and the petitioners filed compromise applications supported by affidavits.

The Principal Registrar verified the parties, their signatures, and the voluntary nature of the compromise, finding no threat, inducement, or coercion.

Whether the High Court should exercise its inherent jurisdiction under Section 528 of the BNSS to quash an FIR alleging an attempt on the complainant’s life with a firearm merely because the parties have entered into a compromise?

Whether the alleged offence, involving two firearm shots fired with an intention to cause death, constitutes a serious offence affecting public interest such that it cannot ordinarily be quashed on the basis of settlement?

The Court applied Section 528 of the BNSS, which preserves the High Court’s inherent jurisdiction to prevent abuse of process and secure the ends of justice.

The Court relied on State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688, which holds that heinous or serious offences, including attempt to murder, should not ordinarily be quashed merely on the basis of compromise, particularly where the offence has a serious societal impact.

It also relied on Vijay Kumar Kela & Anr. v. Central Bureau of Investigation & Anr., 2026 INSC 588, which reiterates that criminal proceedings involving heinous offences, mental depravity, or substantial public interest cannot appropriately be terminated solely because the victim and accused have settled the matter.

Although the compromise was verified as voluntary and was supported by the complainant, the Court assessed the nature and gravity of the alleged occurrence rather than treating the settlement as determinative.

The allegations disclosed that the accused allegedly used a firearm and fired two shots at the injured with the intention of causing his death, one shot striking the back and the other the abdomen.

The Court held that such conduct was not purely private or civil in character and involved a serious offence with an impact upon society at large.

Applying the principles in Laxmi Narayan and Vijay Kumar Kela, the Court concluded that the subsequent compromise did not extinguish the seriousness of the alleged offence or the overriding public interest in prosecuting serious criminal conduct.

The petition was accordingly dismissed, and compromise applications I.A. Nos. 11450/2026 and 11451/2026 were disposed of.

The Court clarified that its observations were confined to the petition and would not prejudice either party before the Trial Court.