Supreme Court Upholds Stringent Stance: Compromise Insufficient to Quash FIR Under SC/ST Act

New Delhi

The Supreme Court of India has firmly reiterated that settlements between parties cannot be the basis for quashing First Information Reports (FIRs) registered under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) .

Justices Vikram Nath and Ahsanuddin Amanullah , presiding over the bench, set aside a Madhya Pradesh High Court order that had quashed an FIR based on a purported compromise between the accused and the complainant.

Case Background: FIR Quashed on Grounds of Settlement

The case originated from an FIR lodged by Mohd. Anis at the Kotwali Police Station in Katni, Madhya Pradesh, on June 16, 2022. The FIR, registered as Crime No. 270/2022 , cited offenses under:

• Sections 294, 323, 506 Part II of the Indian Penal Code (IPC) Sections 3(1)(r) and 3(1)(s) of the SC/ST Act The Madhya Pradesh High Court , in its order dated December 16, 2022, allowed an application under Section 482 of the Criminal Procedure Code (Cr.P.C.) and quashed the FIR, citing a settlement between the involved parties.

Supreme Court's Observation: High Court Erred in Quashing FIR

The Supreme Court stated that the High Court had committed a “grave error” by invoking its inherent powers under Section 482 Cr.P.C. to quash the FIR.

Reliance on Precedent Judgments

The Supreme Court referred to the following judgments:

• Dushyant Somal v. State of NCT of Delhi (2023 SCC Online SC 1479)
• State of Madhya Pradesh v. Laxmi Narayan [(2019) 5 SCC 688]

These cases highlighted that offenses under the SC/ST Act are non-compoundable and cannot be quashed even if a settlement exists.

Excerpts from Judgment

“Heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. cannot be fittingly quashed even though the victim and the offender have settled the dispute.”

Final Verdict and Implications

The Supreme Court set aside the High Court’s judgment and reinstated the FIR (Crime No. 270/2022). The court emphasized that High Courts should exercise caution when handling applications under Section 482 Cr.P.C., particularly in cases involving non-compoundable offenses under special statutes.

This judgment reinforces the stringent legal position against settling cases involving offenses under the SC/ST Act, underscoring their societal impact beyond individual disputes.