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2026 Supreme(Mad) 1142

IN THE HIGH COURT OF JUDICATURE AT MADRAS 
M.NIRMAL KUMAR, J. 
G.Sakthi – Petitioner
Versus
The State, rep. by The Inspector of Police – Respondent
Crl.O.P.No.10740 of 2026 
Decided On : 28-04-2026

Advocates Appeared:
For the Petitioner: Mr.T.Shanmugam
For the Respondent: Mr.Leonard Arul Joseph Selvam Additional Public Prosecutor

Criminal proceedings involving private disputes can be quashed on the basis of compromise arrived between the parties when continuation would be abuse of process.

Headnote:Statute Analysis: The petition is filed under Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023 to quash proceedings under Sections 29(b), 323, 384, 498(A) and 506(i) IPC and Sections 3(1)(s), 3(c)(r) and 3(2)(va) of SC/ST Prevention of Atrocities Act. Facts of the Case: The petitioners faced trial for alleged offences involving atrocities against a Scheduled Caste woman after an inter-caste marriage. The complainant alleged harassment, humiliation, and forcible removal of Thali by the petitioners. Both parties arrived at a mutual compromise and filed a joint settlement memo seeking quashing of proceedings.

Findings of Court:
The Court allowed the quash petition based on the compromise arrived between the parties. The Court accepted the parties' willingness to give quietus to all disputes and held that the continuation of proceedings would serve no useful purpose.

Issues: Whether a criminal case involving alleged SC/ST atrocities and IPC offences can be quashed based on compromise between the parties.

Ratio Decidendi: The Court reasoned that when both parties have arrived at a compromise and the complainant has expressed willingness to withdraw the complaint, continuation of criminal proceedings would amount to abuse of process and would not be in the interest of justice. The Court observed that the dispute between the parties is essentially private in nature.

Result: The Criminal Original Petition stands allowed and the case in Spl.S.C.No.77 of 2025 is quashed against petitioners and all petitioners are discharged from all charges.

Table of Content
1. background of inter-caste marriage and alleged offenses filed. (Para 2 , 3)
2. arguments on both sides regarding harassment and consent. (Para 4 , 5)
3. court accepts compromise and quashes the case. (Para 6 , 7)

ORDER :

M.NIRMAL KUMAR, J.

The petitioner/accused in Spl.S.C.No.77 of 2025 facing trial for the offence under Sections 29(b), 323, 384, 498(A) and 506(i) IPC and Sections 3(1)(s), 3(c)(r) and 3(2)(va) of SC/ST Prevention of Atrocities Act filed this quash petition.

2.The case of the prosecution is that the defacto complainant, a resident of Adaiyur Village, Tiruvannamalai District belonged to Hindu Adi Dravidar Scheduled Caste community, the petitioners 1 to 3 residing in Vannur, Villupuram District and the petitioners 4 and 5 are residing at Lawspet, Puducherry. The defacto complainant, a M.Sc (Maths) graduate employed as Mathematics Teacher in TVS Academy School, Adaiyur Village for three years prior to 2020. She frequently visits Ramanashram, Tiruvannamalai. During one such visit in the month of March 2020 the petitioner met the defacto complainant and introduced him as Sakthi, hailing from Vanur, Villupuram running a Travels business at Auroville. The defacto complainant informed the first petitioner not to engage such talks with her and she left the place. During the month of April 2020, the first petitioner went to the School to drop a parent and saw the defacto complainant, again spoke with her and collected her phone number. On 10.04.2020, the first petitioner informed the defacto complainant of his intention to marry her. The defacto complainant refused the proposal and informed petitioner that she belonged to Scheduled Caste community, whereas the first petitioner belonged to the Vanniyar, Most Backward Community, and will not be accepted by her family. She also informed not to disturb her. But they continued to remain in contact. Subsequently, when the defacto complainant’s father arranged marriage for her with one Ilayaraja, a Government School Teacher, the defacto complainant unwilling for the marriage, consumed Lizol cleaning acid and she was rushed to the hospital and saved. Thereafter, on 10.02.2022 the fourth petitioner called the defacto complainant and asked her to come home, believing her words, the complainant went to Kuyilapalayam without informing her parents. On 11.02.2022, marriage arranged between the defacto complainant and first petitioner at Manakula Vinayagar Temple, Puducherry and marriage was registered at Cuddalore on 12.02.2022.

3.Initially, the defacto complainant’s parents were shocked on coming to know about the marriage and later, they accepted the reality and arranged a reception at Hotel Vijay Park, Tiruvannamalai, on 21.02.2022, at that time, expected Sridhana articles could not be presented and promised that Sridhana articles would be given after a month. On 23.02.2022, the first petitioner called the victim's parents and demanded Sridhana articles, thereafter trouble started. One month after the marriage, the defacti complainant found that the petitioners' family was more focused on wealth and on her earnings and not treated her with love and affection. She was humiliated citing her social status. She was locked inside a room and prevented from speaking with others. When the defacto complainant earlier called her parents and informed about humiliation, they pacified but later her mobile phone was snatched and damaged by the petitioner. Thereafter, second mobile phone was given to her by victim’s mother, which was also damaged on the allegation that she was informing her parents about the harassment. The petitioners took the defacto complainant forcibly in a car, removed her Thali and pushed her out of the car and left the place. Thereafter, complaint lodged, FIR registered and on completion of investigation, charge sheet filed listing 13 witnesses and the case is now at the trial stage.

4.The learned counsel for the petitioners submitted that even going by the unco

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