High Courts may exercise inherent powers to quash criminal proceedings based on a settlement between parties if the dispute is predominantly private/civil and the likelihood of conviction is remote, thereby preventing abuse of the process of law.

By the Court:- Heard the parties.

2. This criminal miscellaneous petition has been filed invoking the jurisdiction of this Court under Section 528 of BNSS with the prayer for quashing and setting aside the entire criminal proceeding including the FIR in connection with Barkatha P.S. case no. 176 of 2024 registered for the offences punishable under Sections 191 (2), 191 (3), 190, 118(1), 109 of BNS, pending in the court of learned JMFC, Hazaribag.

3. Learned counsel for the petitioner and learned counsel for the opposite party no. 2- informant victim jointly drawing attention of the court to the Interlocutory Application no. 16720 of 2025, which is supported by separate affidavits of the petitioner as well as the opposite party no. 2- informant submitted that therein it has categorically been mentioned that the dispute between the parties has already been settled outside the court, hence, the informant does not want to proceed with the case. It is next submitted that both the parties are residing in the same locality in the neighbourhood. It is next submitted that the occurrence took place on the sudden provocation in respect of a petty issue of grazing of cattle in the field but the petitioner had no intention to kill anybody. It is further submitted that the dispute between the parties is a private dispute and no public policy is involved in the present case. It is further submitted that the allegations against the petitioner are all false. It is further submitted that in view of the full and final settlement between the petitioner and the opposite party no. 2, the opposite party no. 2 is not desirous to proceed with the case and the chance of the conviction of the petitioner is remote and bleak hence, continuation of the criminal proceeding will amount to abuse of the process of the court, hence, it is submitted that entire criminal proceeding including the FIR in connection with Barkatha P.S. case no. 176 of 2024 be quashed and set aside.

4. Learned Addl. PP submits that the State has no objection to the prayer of the petitioners to quash and set aside the entire criminal proceeding including the FIR in connection with Barkatha P.S. case no. 176 of 2024 in view of the compromise between the parties.

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 of Narinder Singh and Others vs. State of Punjab & Another reported in (2014) 6 SCC 466, in paragraph 29, has 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 matter between themselves. However, this power is to be exercised sparingly and with caution.

29.2. W