Settlement of Primarily Private Disputes Compels Quashing of SC/ST Act Offenses to Prevent Abuse of Process

The Petitioner sought the quashing of FIR No. 0386/2025 registered at PS Badar Pur under Sections 115, 126(2), 74, 78, 324(2), and 351(2) of the Bharatiya Nyaya Sanhita (BNS), 2023.

These correspond to Sections 323, 341, 354, 354D, 426, and 506 of the IPC.

Section 2(1)(r)(s) of the SC/ST (Prevention of Atrocities) Act, 1989 was subsequently added.

Respondent No. 2 (complainant) alleged that the Petitioner harassed her, threatened her family, blocked her vehicle, used casteist remarks, and assaulted her inappropriately in public.

During the proceedings, the parties reached an amicable settlement following an apology by the Petitioner.

The complainant expressed her desire not to pursue the case, confirming the settlement was voluntary.

1. Whether the High Court can exercise its inherent powers to quash criminal proceedings involving offences under the SC/ST Act on the basis of a private settlement between parties.

2. Whether the continuation of the present FIR would serve any useful purpose given the settlement and the complainant's statement.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which grants inherent powers to the High Court to prevent abuse of process or secure the ends of justice.

The precedent set in Ramawatar v. State of M.P. (2022), which established that while courts must be circumspect with special statutes like the SC/ST Act, they may quash proceedings if the offence is primarily private in nature, not committed purely on account of caste, and if the settlement does not contravene the underlying objective of the Act.

The Court observed that the Respondent No. 2 had voluntarily entered into a settlement after receiving an apology from the Petitioner.

The Court noted that the Dispute was essentially personal, and the complainant no longer wished to pursue the matter.

Relying on the principles in Ramawatar, the Court reasoned that if a settlement is reached and the victim willingly participates, continuing the prosecution would be an exercise in futility as the chances of conviction would be "minuscule".

The Court emphasized that forcing the continuation of the trial would cause unnecessary acrimony between the parties and place an avoidable burden on the State exchequer.

The Court held that quashing was necessary to secure the ends of justice as the parties had settled their private grievances.

The relief was granted subject to the Petitioner depositing a cost of ₹50,000/- with the Delhi High Court Legal Services Committee within four weeks and parties were directed to submit original affidavits and the Memorandum of Understanding to the concerned Investigating Officer.