The court ruled that criminal proceedings can be quashed based on compromise when offences are predominantly private in nature, ensuring justice and voluntary settlement.

ORDER

This Criminal Original Petition is filed under Section 482 CrPC /

Section 528 BNSS, seeking to quash the First Information Report in Crime No. 41 of 2018 on the file of the 1^st respondent Police Station, insofar as the petitioners are concerned.

2. The prosecution case is that on 15.03.2018 at about 11.00 p.m., while the defacto complainant was returning home along with his employee after closing his hotel at Devipattinam Bazaar, the accused persons allegedly abused him in filthy language, assaulted him and kicked him, causing internal injuries, and also stole a sum of Rs. 32,050/- from his vehicle. Based on the said allegations, F.I.R. in Crime No.41 of 2018 was registered on the file of the 1^st respondent police for the offence under Sections 296(b), 323, 379 and 506(1) IPC.

3. Admittedly, the petitioner and the 2^nd respondent are residing in the same locality, and they have now resolved the dispute amicably.

A Joint Compromise Memo dated 20.02.2026 has been filed before this Court.

4. The petitioner and the 2^nd respondent / defacto complainant are present before this Court in person and are identified by Mr.T.Perumalpillai, SSI, Devipattinam Police Station, Ramanathapuram District. The defacto complainant has categorically stated that he 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 Punjab¹, 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

1 2012 10 SCC 303 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 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 cas