Quashing of FIR — Inherent Powers under Section 482 Cr.P.C. / Section 528 BNSS — Compromise between Parties. (Paras 1–3, 5) Petitioners/A1 to A7 sought quashing of FIR No.75 of 2025 registered for offences under Sections 115(2), 118(1), 352(2) r/w 3(5) of the Bharatiya Nyaya Sanhita, 2023 and Sections 3(2)(va), 3(1)(r), 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The de facto complainant appeared before Court, was identified, and categorically stated that compromise was voluntary and without coercion. Court recorded satisfaction regarding voluntariness and identity. Ratio Decidendi: The High Court, in exercise of inherent jurisdiction under Section 482 Cr.P.C. (corresponding to Section 528 BNSS), may quash criminal proceedings where parties have voluntarily settled the dispute and continuation of proceedings would serve no useful purpose.

advocatemmmohan

Quashing of FIR — Inherent Powers under Section 482 Cr.P.C. / Section 528 BNSS — Compromise between Parties. (Paras 1–3, 5)

Petitioners/A1 to A7 sought quashing of FIR No.75 of 2025 registered for offences under Sections 115(2), 118(1), 352(2) r/w 3(5) of the Bharatiya Nyaya Sanhita, 2023 and Sections 3(2)(va), 3(1)(r), 3(1)(s) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The de facto complainant appeared before Court, was identified, and categorically stated that compromise was voluntary and without coercion. Court recorded satisfaction regarding voluntariness and identity.

Ratio Decidendi: The High Court, in exercise of inherent jurisdiction under Section 482 Cr.P.C. (corresponding to Section 528 BNSS), may quash criminal proceedings where parties have voluntarily settled the dispute and continuation of proceedings would serve no useful purpose.

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Scope of Inherent Power Distinguished from Compounding under Section 320 Cr.P.C. — Application of Gian Singh Principle. (Para 4)

The Court relied upon the principles laid down by the Supreme Court in Gian Singh v. State of Punjab, particularly paragraph 57, holding that inherent powers are distinct from statutory compounding and may be exercised to secure ends of justice or prevent abuse of process.

The Court emphasized that quashing on compromise depends on nature and gravity of offence. Heinous offences and those having serious societal impact cannot ordinarily be quashed merely on compromise.

Ratio Decidendi: Inherent jurisdiction to quash is guided by twin objectives — securing ends of justice and preventing abuse of process — and must consider nature and gravity of the offence before exercising discretion.

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Effect of Compromise — Remote Possibility of Conviction — Abuse of Process. (Paras 3, 5)

Upon recording compromise and considering the factual matrix, the Court concluded that chances of conviction were remote and bleak, and continuation of proceedings would amount to oppression and prejudice.

Ratio Decidendi: Where compromise renders possibility of conviction remote and continuation of prosecution would amount to abuse of process, High Court is justified in terminating criminal proceedings.

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Offences under Special Statutes — Exercise of Discretion. (Para 4, contextual application)

Although offences included provisions under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, the Court, after satisfaction regarding compromise and factual context, exercised discretion to quash proceedings.

Ratio Decidendi: Even where offences are under special statutes, the High Court retains inherent jurisdiction; however, exercise of such power must be based on careful scrutiny of facts and voluntariness of settlement.

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Final Order

Criminal Petition No.1502 of 2026 allowed.
Proceedings in FIR No.75 of 2025 of Voyalapadu Police Station, Annamayya District quashed.
I.A. Nos.2 and 3 of 2026 allowed.
Pending interlocutory applications closed.