Settlement and abatement of principal offender's case justify quashing conviction in long-standing compoundable disputes.

The applicants were originally accused of assault in a 2001 incident.

The Trial Court (JMFC) acquitted them on May 10, 2013, citing lack of specific evidence and contradictions, granting the benefit of doubt.

On appeal, the 3rd Additional Sessions Judge, Mahesana, reversed this on July 2, 2015, convicting the applicants under Sections 323, 324, 325, and 326 read with Section 114 of the IPC, sentencing them to two years of simple imprisonment.

During the pendency of this revision application, Applicant No. 1 (the main assailant who used an axe) died, and the remaining applicants reached an amicable settlement with the injured eye-witnesses.

1. Whether the conviction of the applicants should be set aside in light of an amicable settlement between the parties, particularly regarding the non-compoundable offence under Section 326 of the IPC.

2. Whether the abatement of the case against the primary accused (Applicant No. 1) affects the liability of the remaining applicants under Sections 326/114 of the IPC.

The court primarily considered Section 397 of the CrPC regarding revisional jurisdiction and Section 320 of the CrPC concerning the compounding of offences.

It applied the principle that while certain offences (like Section 326 IPC) are non-compoundable, the High Court may exercise its inherent or revisional powers to quash proceedings based on a settlement to restore harmony, especially in long-standing private disputes.

The court specifically relied on the precedent of *H.N. Pandakumar v. State of Karnataka* (2025 INSC 37) regarding the impact of settlements on criminal convictions.

The Court noted that the litigation had lasted for 26 years (since 2001) and that the parties had now reached a genuine settlement.

While the Appellate Court had reversed the initial acquittal based on eye-witness testimony, the High Court observed that the primary allegations regarding the "grievous hurt" (Section 326) were attributed to Applicant No. 1, whose case had abated due to his death.

Considering that the Trial Court had originally granted the benefit of doubt and the current willingness of the victims to settle, the Court reasoned that insisting on incarceration after two decades would serve no purpose.

It determined that restoring relationships through compromise was more appropriate than continuing the punishment for the surviving applicants.

The judgment and order of conviction dated July 2, 2015, passed by the 3rd Additional Sessions Judge, Mahesana, was quashed and set aside.

Consequently, the original judgment of acquittal dated May 10, 2013, passed by the Judicial Magistrate First Class, was confirmed.

The applicants were discharged from their liabilities.