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2026 Supreme(Raj) 247

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN AT JAIPUR
ANUROOP SINGHI, J.
Surendra Singh @ Surendra Gurjar S/o Shri Uday Singh Gurjar – Appellant
Versus
State of Rajasthan – Respondent
S.B. Criminal Miscellaneous (Petition) No. 2835 of 2026
Decided On : 14-05-2026

Advocates Appeared:
For the Appellants : Suresh Kumar, Vijay Laxmi Jangid
For the Respondents: Manvendra Singh Shekhawat, Amitesh Rana, Digvijay Jhalani

The High Court may exercise its inherent powers to quash criminal proceedings for non-compoundable offences where the dispute is private and personal, the parties have reached an amicable settlement, and the offence does not significantly impact society, thereby preventing an abuse of the process of law.

Headnote:(A) Bharatiya Nagarik Suraksha Sanhita, 2023 - Section 528 - Bharatiya Nyaya Sanhita, 2023 - Sections 287 and 324(5) - Quashing of criminal proceedings - Inherent powers of High Court - Compromise between parties - Dispute of private and personal nature - Absence of serious impact on society - Exercise of inherent powers to prevent abuse of process of law. (Paras 7, 8)

Facts of the case:
The petitioners sought the quashing of an FIR registered for offences related to negligence and property damage. The parties involved reached an amicable settlement, and the complainant expressed no objection to the quashing of the proceedings. The investigating officer confirmed the compromise, and there were no prior criminal antecedents against the petitioners.

Findings of Court:
The court observed that the dispute was essentially private and personal in nature. Given the amicable settlement and the lack of any subsisting grievance, the court concluded that the continuation of criminal proceedings would serve no purpose and would constitute an abuse of the process of law.

Issues: Whether criminal proceedings for non-compoundable offences can be quashed by the High Court in exercise of its inherent powers when the parties have arrived at a compromise.

Ratio Decidendi: The High Court, in exercise of its inherent powers, can quash criminal proceedings even in respect of non-compoundable offences if the dispute is essentially of a private and personal nature and the parties have amicably settled the matter, provided that such offences do not have a serious impact on society.

Result: Petition allowed; FIR and all consequential proceedings quashed.

Table of Content
1. parties seeking fir quashing based on a mutual compromise agreement. (Para 1 , 2 , 3 , 4)
2. factual basis of fir and verification of the settlement status. (Para 5 , 6)
3. high court's inherent power to quash criminal proceedings for settled private disputes. (Para 7 , 8)
4. formal order quashing the fir and closing all proceedings. (Para 9 , 10)

ORDER :

1. The present criminal miscellaneous petition has been filed by the petitioners under Section 528 of B.N.S.S., 2023 seeking quashing of FIR No.0110/2026 dated 05.03.2026 registered at Police Station Kho Nagoriyan, District Jaipur City (East), for the alleged offences punishable under Sections 287 and 324(5) of B.N.S., 2023 and all consequential proceedings arising therefrom.

2. Learned counsel for the petitioners, at the very outset, submit that the FIR in question arises out of an inter-se dispute between the parties and as the parties have arrived at a compromise dated 30.04.2026, a copy of which has been annexed with the petition as Annexure-2, the FIR in question deserves to be quashed in view of the judgments passed by the Hon’ble Supreme Court in Gian Singh Vs. State of Punjab & Anr. (2012) 10 SCC 303, Narinder Singh & Ors. Vs. State of Punjab & Anr., (2014) 6 SCC 466 and State of Madhya Pradesh Vs. Laxmi Narayan & Ors., (2019) 5 SCC 688.

3. Learned counsel appearing for respondent No.2-complainant while acknowledging the factum of compromise between the parties submits that the respondent No.2-complainant has willingly arrived at the said compromise and has no objection if the FIR in question is quashed.

4. Learned Public Prosecutor has handed over the factual report dated 12.05.2026 submitted by the concerned Investigating Officer, wherein the factum of compromise being entered into between the parties has been confirmed and thus, he submits that in view of the compromise entered into between the parties, appropriate order be passed.

5. Heard learned counsel for the parties and perused the record.

6. Perusal of the Impugned FIR reveals that the same was lodged by the respondent No.2-complainant alleging that he had taken a shop on rent from petitioner No.2-Dinesh Meena. The FIR further states that petitioner No.2-Dinesh Meena was very much aware that in the adjacent shop, an illegal activity of filling of gas cylinders was being carried out which was also informed by the respondent No.2-complainant to Dinesh Meena, however, no action was taken by him. Unfortunately on 04.03.2026, one of the cylinders exploded, resulting into fierce fire on account of which material lying in the shop of the complainant also got destroyed.

7. However, the parties have now entered into a compromise which records that a certain amount has been received by the respondent No.2-complainant towards compensation for the loss suffered by him and consequently, the controversy has been amicably settled between the parties.

6. In pursuance to the order dated 07.05.2026 passed by this Court, the Investigating Officer was directed to submit the status report with respect to the compromise entered into between the parties. Factual report dated 12.05.2026 in that regard has been received and is taken on record, wherein the Investigating Officer has confirmed the factum of compromise being entered into between the parties. The antecedents of the petitioners have also been placed on record which reveals that there are no pending cases against any of the petitioners.

7. From the material on record, it is apparent that the dispute has amicably been settled between the parties. The Hon’ble Supreme Court in Gian Singh (supra), has authoritatively held that the High Court in exercise of its inherent powers under Section 482 Cr.P.C. can quash criminal proceedings even in respect of non-compoundable offences if the dispute is essentially of a private and personal nature and the parties have amicably settled the matter, provided that such offences do not have a serious impact on society. The above mentio

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