The High Court may exercise its inherent powers under Section 482 CrPC to quash criminal proceedings involving serious offences, including those under Section 69 BNS, where the parties have reached an amicable settlement, the trial has not commenced, and continuation of the proceedings serves no useful purpose.

1. By way of the present petition, the petitioner, who is the accused in proceedings arising out of FIR No. 227/2025 registered at Police Station D.B.G. Road for the alleged offence under Section 69 of the Bharatiya Nyaya Sanhita, 2023 [“BNS”], seeks quashing of the said FIR and all proceedings emanating therefrom.

2. The FIR was registered at the instance of respondent No. 2 on 14.06.2025. The allegation against the petitioner is that he first met the complainant [respondent No. 2 herein] in October 2024 and that, from 27.12.2024 onwards, he persuaded respondent No. 2 to enter into a sexual relationship on the false promise of marriage.

3. The allegations pertain to a period during which respondent No. 2 was approximately 28 years of age, and the petitioner was approximately 29 years of age.

4. The present petition is premised on the amicable resolution of disputes between the parties. An affidavit dated 19.08.2025, in the nature of a No Objection Certificate [“NOC”], has been filed by respondent No. 2 and annexed to the petition. In the said affidavit, respondent No. 2 states that the allegations arose out of a wrong and mistaken impression about the petitioner, which has since been clarified. She has further stated that the parties are unable to solemnise a matrimonial alliance due to opposition from their respective families.

5. The petitioner and respondent No. 2 are both present before the Court, and have been identified by their respective counsel, as well as by the Investigating Officer [“IO”].

6. Petitions seeking quashing of criminal proceedings on the ground of compromise are ordinarily not entertained in cases involving offences of heinous nature, including rape. However, the Supreme Court has held that this principle is not absolute, and the High Court must examine the facts and circumstances of each case in a holistic and judicious manner.

7. In Kapil Gupta v. State (NCT of Delhi) [(2022) 15 SCC 44] [hereinafter, “Kapil Gupta”], the Supreme Court considered the challenge to a decision of this Court declining to quash criminal proceedings, including those under Section 376 Indian Penal Code, 1860 [“IPC”], on the ground of settlement. Upon being satisfied that the settlement had been entered into voluntarily by the complainant, and after considering its earlier judgments, including Narinder Singh v. State of Punjab [(2014) 6 SCC 466] [hereinafter, “Narinder Singh”], the Court observed as follows:

“12. It can thus be seen that this Court has clearly held that though the Court should be slow in quashing the proceedings wherein heinous and serious offences are involved, the High Court is not foreclosed from examining as to whether there exists material for incorporation of such an offence or as to whether there is sufficient evidence which if proved would lead to proving the charge for the offence charged with. The Court has also to take into consideration as to whether the settlement between the parties is going to result into harmony between them which may improve their mutual relationship.

13. The Court has further held that it is also relevant to consider as to what is the stage of the proceedings. It has been observed that if an application is made at a belated stage wherein the evidence has been led and the matter is at the stage of arguments or judgment, the Court should be slow to exercise the power to quash the proceedings. However, if such an application is made at an initial stage before commencement of trial, the said factor will weigh with the court in exercising its power.

14. The facts and circumstances as stated hereinabove are peculiar in the present case. Respondent 2 is a youn