Serious offences involving sexual exploitation and SC/ST Act violations cannot be quashed based on compromise.

The petitioner filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), seeking to quash FIR Crime No. 17/2026 registered at Police Station Bhind Dehat.

The FIR alleged offences under Sections 69 and 351(3) of the Bharatiya Nyaya Sanhita (BNS) and Sections 3(1)(w)(i), 3(2)(v), and 3(2)(va) of the SC/ST Act.

The petitioner and the complainant (Respondent No. 2) filed interlocutory applications (I.A. Nos. 3875/2026 and 3876/2024) stating they had reached an amicable settlement and no longer wished to pursue the criminal case.

The State opposed the quashment, arguing the offences were non-compoundable, serious, and against society.

Whether a criminal proceeding involving allegations of sexual intercourse by deceitful means (Section 69 BNS) and offences under the SC/ST Act can be quashed by the High Court under its inherent powers based on a private compromise between the parties.

The court applied Section 528 of the BNSS (analogous to Section 482 of the Cr.P.C.) regarding the inherent powers of the High Court.

It relied on the principle that Section 69 of the BNS—dealing with sexual intercourse by deceitful means or false promises of marriage—is analogous to rape.

The court further applied the precedents of Narendra Singh v. State of Punjab (2014), Parbatbhai Aahir v. State of Gujarat (2017), and State of M.P. v. Laxmi Narayan (2019), which establish that while High Courts can quash proceedings to prevent abuse of process, heinous and serious offences (murder, rape, dacoity) or crimes against society cannot be quashed merely on the basis of a settlement.

The court reasoned that Section 69 of the BNS involves sexual exploitation through coercion or fraud, making it a serious offence against society rather than a purely private dispute.

Applying the guidance from Narendra Singh and Laxmi Narayan, the court noted that the inherent power to quash must be exercised sparingly and is generally reserved for cases that are predominantly civil, matrimonial, or commercial in nature.

The court observed that the gravity of the allegations under the BNS and the SC/ST Act transcends the realm of an individual grievance and impacts public order.

Consequently, the court found that the settlement between the parties was insufficient to override the societal interest in prosecuting such heinous acts.

The court concluded that the petition was devoid of merit and dismissed it, refusing to exercise its inherent powers under Section 528 of the BNSS.