The inherent power of the High Court under Section 482 CrPC can quash criminal proceedings based on voluntary compromise in predominantly private disputes.

ORDER

This Criminal Original Petition is filed under Section 482 CrPC / Section

528 BNSS, seeking to quash the proceeding in S.C.No.176 of 2025 on the file of the learned II Additional Subordinate Judge at Nagercoil, Kanyakumari District, as illegal.

2. The gist of the allegations in the FIR is that, due to previous enmity, on 14.02.2023 at about 08.15 pm., when the defacto complainant was riding along with his friend in a two-wheeler bearing Registration No.TN 74 AV 5967 near Pannaiyur Bridge, the petitioners waylaid them, abused the defacto complainant using filthy language and assaulted the defacto complainant with an aruval and iron rod. Based upon the complaint given by the defacto complainant, FIR in Crime No.38 of 2023 was registered by the first respondent for the offences under Sections 147, 341, 294(b), 324, 307 and 506(2) of IPC. After completion of investigation, charge sheet has also been filed and the same was taken cognizance in S.C.No.176 of 2025.

3.Admittedly, the petitioners and the second respondent are known to each other and they have now resolved the dispute amicably. A Joint Compromise Memo dated 27.02.2026 has been filed before this Court.

4.The petitioners and the second respondent / defacto complainant are present before this Court in person and are identified by Matheesh, Head Constable, Rajakkamangalam Police Station. The defacto complainant has categorically stated that he does not wish to pursue the impugned proceeding against the petitioners. This Court is satisfied that the compromise is voluntary and not the result of any coercion or undue influence.

5.The law relating to quashment of criminal proceedings on the basis of compromise between the parties is well settled. In Gian Singh v. State of Punjab, 2012 10 SCC 303, the Hon’ble Supreme Court authoritatively held that the inherent power of the High Court under Section 482 CrPC is of wide amplitude and may be exercised to quash criminal proceedings even in respect of non- compoundable offences, provided the dispute is essentially private in nature and the quashment would secure the ends of justice. The Court, however, drew a clear distinction between offences arising out of personal or matrimonial disputes, commercial transactions and similar private wrongs, and serious or heinous offences having grave impact on society, holding that the latter category cannot ordinarily be quashed merely on the basis of a settlement.

6.The said principles were succinctly crystallised in Parbatbhai Aahir v.

State of Gujarat, 1(2017) 9 SCC 641, wherein the Supreme Court, after surveying the earlier precedents, laid down broad propositions governing the exercise of inherent jurisdiction on the basis of compromise. It was emphasised that the paramount consideration is whether the continuance of the criminal proceedings would be unfair or contrary to the interests of justice, and whether the dispute predominantly bears a civil or private character, rendering the possibility of conviction remote and bleak.

7.In State of Madhya Pradesh v. Laxmi Narayan², the Supreme Court reiterated and clarified the limitations on such power, holding that offences of a serious nature, particularly those involving mental depravity, grave violence, or offences against society at large, cannot be quashed on the basis of compromise, even if the parties have amicably settled the dispute. The Court further cautioned that while examining compromise quash petitions, the High Court must consider the nature and gravity of the offence, the conduct of the accused, and the stage of the proceedings,and the overall impact on society and must satisfy itself that the settlement is voluntary and not the result of coercion

or undue influence. 2(2019) 5 SCC 688

8.Applying the aforesaid principles to the fa