Criminal proceedings can be quashed based on compromise if the dispute is private and does not pose serious societal harm.

ORDER

This Criminal Original Petition is filed under Section 482 CrPC /

Section 528 BNSS , seeking to quash the F.I.R in Crime No.241 of 2025 on the file of the 1^st respondent police station, insofar as the petitioners are concerned.

2. The case of the prosecution is that, due to previous enmity between the Petitioners and the 2^nd respondent/Defacto Complainant, on 28.07.2025 at about 9.00 p.m., the accused allegedly chased the defacto complainant’s sons with an intention to assault them. The defacto complainant’s second son and her nephew are stated to have escaped and taken shelter inside the defacto complainant’s house, following which her husband closed the grill gate. It is further alleged that Accused No.1 abused the defacto complainant’s husband in filthy language, attacked him with a knife causing injuries, and criminally intimidated him. Based on the complaint, the Respondent Police registered an FIR on 31.07.2025 for offences under Sections 191(2), 191(3), 296(b), 118(1) and 351(3) of BNS, 2023.

3. Admittedly, the petitioners and the 2^nd respondent are residing in the same locality, 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 2^nd respondent / defacto complainant are present before this Court in person and are identified by Mr.R.Senthil Kumar, SSI, South Gate Police Station, Madurai District. The defacto complainant has categorically stated that she does not wish to pursue the FIR against the petitioner. 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 ¹, 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 , (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

1 2012 10 SCC 303 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 Narayan , (2019) 5 SCC 688 , 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.

8. Applying the aforesaid principles to the facts of the present case, this Court has carefully examined the nature and gravity of the allegations, the relationship between the parties, the cond