The court can quash criminal proceedings when a private dispute is resolved through compromise, indicating a remote chance of conviction and preventing abuse of the legal process.

JUDGMENT :

ANIL KUMAR CHOUDHARY, J.

1. Heard the parties.

2. This criminal miscellaneous petition has been filed invoking the jurisdiction of this Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 with the prayer to quash the entire criminal proceeding in connection with G.R. Case No. 287 of 2025 (S.T. No. 118 of 2025) arising out of Pratappur P.S. Case No. 13 of 2025 as well as the order dated 25.03.2025, passed by the learned Sub Divisional Judicial Magistrate, Chatra in connection with the said G.R. Case No. 287 of 2025 (S.T. No. 118 of 2025) arising out of Pratappur P.S. Case No. 13 of 2025 whereby and where under the learned Sub Divisional Judicial Magistrate has found prima facie case for the offences punishable under Section 109(1), 118(1), 238(b) & 3(5) of the B.N.S., 2023.

3. The learned counsel for the petitioner and the learned counsel for the opposite party no.2, jointly drawing attention of this Court to the Interlocutory Application No.57 of 2026, which is supported by the separate affidavits of the petitioner and the informant-opposite party no.2, submits that therein it has categorically been mentioned that both the parties have compromised the case outside the court and good relationship has been established between the parties, hence the informant does not want to proceed with the case. The learned counsel for the petitioner submits that in view of the compromise between the parties, the continuation of this criminal proceeding will amount to abuse of process of law, as in view of the compromise, the chance of conviction of the petitioner is remote and bleak. It is next submitted that in view of the compromise between the parties, the informant-opposite party no.2 does not want to proceed with the case. It is then submitted that otherwise also the offence punishable under Section 109(1) of the B.N.S., 2023 is not made out against the petitioner and the only allegation against the petitioner is of catching hold of the hair of the informant-victim and driving her out from the Scorpio vehicle. Hence, it is submitted that the prayer as prayed for by the petitioner in this criminal miscellaneous petition be allowed.

4. Learned Addl. P.P. submits that in view of the compromise between the parties, the State has no objection to the prayer as prayed for by the petitioner in this criminal miscellaneous petition.

5. Having heard the submissions made at the Bar and after going through the materials available in the record, it is pertinent to mention here that the Hon’ble Supreme court of India in the case ofNarinder Singh and Others vs. State of Punjab & Another reported in(2014) 6 SCC 466 , in paragraph 29, had laid down the principles by which, the High Court would be guided in giving adequate treatment to the settlement between the parties, and exercising its power under Section 482 Cr.P.C. while accepting the settlement and quashing the proceedings which, reads as under:

“29. In view of the aforesaid discussion, we sum up and lay down the following principles by which the High Court would be guided in giving adequate treatment to the settlement between the parties and exercising its power under Section 482 of the Code while accepting the settlement and quashing the proceedings or refusing to accept the settlement with direction to continue with the criminal proceedings:

29.1. Power conferred under Section 482 of the Code is to be distinguished from the power which lies in the Court to compound the offences under Section 320 of the Code. No doubt, under Section 482 of the Code, the High Court has inherent power to quash the criminal proceedings even in those cases which are not compoundable, where the parties have settled the matt