Voluntary settlement and remote conviction prospects justified quashing non-compoundable family-dispute proceedings.

The petitioners, accused in Bilagi Police Station Crime No. 108/2024, sought to quash the proceedings in C.C. No. 38/2025 for offences under Sections 143, 147, 148, 341, 323, 324, 354, 354(B), 109, 504 and 506(2), read with Section 149 of the IPC.

The complainant and the petitioners stated that they were relatives and had amicably settled their dispute with the intervention of family and community elders.

They jointly applied to compound the offences and sought quashing of the proceedings; the Court recorded that the alleged offences were non-compoundable.

1. Whether the High Court should exercise its inherent jurisdiction to quash criminal proceedings for non-compoundable offences in light of the parties’ settlement.

2. Whether, on the facts and settlement, continuation of the prosecution would constitute an abuse of process when the likelihood of conviction was considered remote.

The Court considered the inherent power under Section 482 of the Code of Criminal Procedure, corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, and distinguished that power from statutory compounding under Section 320 CrPC and Section 359 BNSS.

Relying on Narinder Singh v. State of Punjab, (2014) 6 SCC 466, particularly paragraphs 31–35, it applied the principles that the High Court may quash non-compoundable offences following settlement where doing so serves the ends of justice or prevents abuse of process; the power must be exercised cautiously, having regard to the nature of the offences, the circumstances of the dispute, the stage of proceedings, and the prospects of conviction.

The Court treated the dispute as a family matter that had been voluntarily settled with the assistance of elders, and accepted the parties’ statements that the settlement was free from coercion.

It further found that the charge-sheet did not clearly establish the individual roles of the accused or a direct nexus to the complainant’s allegations, and that the settlement made it unlikely that witnesses would support the prosecution.

In those circumstances, it considered the prospects of conviction remote and continuation of the case unnecessary and an abuse of process.

It quashed the entire proceedings in C.C. No. 38/2025 arising from Crime No. 108/2024, including the charges under Sections 143, 147, 148, 341, 323, 324, 354, 354(B), 109, 504 and 506(2), read with Section 149 IPC, and allowed I.A. No. 1/2026 accordingly.