The Supreme Court has declined to interfere with a Punjab and Haryana High Court order quashing criminal proceedings against accused persons after they entered into a compromise with the complainant, even though the accused had already been convicted by the trial court.

A Bench of Justices Prashant Kumar Mishra and Shree Chandrashekhar, in its judgment dated August 25, 2026, held that the case involved an incident between individuals and did not concern a heinous offence, economic offence, large-scale scam or an offence involving contraband under the NDPS Act.

The case arose from FIR No. 249 dated August 25, 2005, registered at Police Station Abohar, District Ferozepur (now Fazilka), under Sections 364, 325, 324 and 323 of the IPC.

The respondents had subsequently been convicted by the Additional Sessions Judge, Ferozepur, by an order dated May 9, 2012, for offences under Sections 365/149, 324/149, 325/149 and 148 IPC and sentenced to imprisonment and fine.

High Court Quashed Proceedings After Compromise

Following their conviction, the accused approached the High Court under Section 482 of the Code of Criminal Procedure, relying upon a compromise reached with the complainant.

The High Court directed the trial court to record the statements of the parties. The complainant/victim informed the court that the compromise had been voluntarily entered into with the intervention of relatives and respectable persons and that it was genuine and free from pressure or undue influence.

Relying upon the Supreme Court's decision in Gian Singh v. State of Punjab, the High Court subsequently quashed the FIR and all consequential proceedings, including the conviction.

The State of Punjab challenged that order before the Supreme Court.

Supreme Court Reiterates Limits on Post-Conviction Quashing

The Supreme Court referred to its earlier decisions in Narinder Singh v. State of Punjab and Ramgopal v. State of Madhya Pradesh, which recognise that the High Court's inherent power under Section 482 CrPC is distinct from the statutory power of compounding offences under Section 320 CrPC.

The Court reiterated that criminal proceedings involving non-heinous offences or offences predominantly of a private nature may, in appropriate cases, be quashed even after the trial has concluded and the accused has been convicted.

However, such extraordinary power must be exercised carefully after considering the nature and seriousness of the offence, the effect of the offence on society, the genuineness and voluntary nature of the compromise and the conduct of the accused.

The Court also reiterated that heinous or serious offences, offences involving moral turpitude, offences having a harmful impact on the social fabric, and matters involving public policy cannot ordinarily be wiped out merely on the basis of a settlement between the parties.

No Interference Warranted in Present Case

Applying these principles, the Bench found that the present case did not involve a very heinous offence. The Court specifically noted that it was not an economic offence, did not involve contraband under the NDPS Act and was not a large-scale scam involving the public at large.

The Supreme Court therefore concluded that there was no reason to interfere with the High Court's decision to quash the criminal proceedings.

Accordingly, the appeal filed by the State of Punjab was disposed of, with pending applications, if any, also disposed of.

The Supreme Court has reaffirmed that a post-conviction compromise can, in appropriate cases involving non-heinous and predominantly private offences, justify quashing of criminal proceedings under Section 482 CrPC. However, the power must be exercised sparingly and after examining the nature of the offence, its impact on society and the genuineness of the settlement.

Representation:-

For Appellant(s) : Mr. Rajat Bhardwaj, A.A.G. Mr. Karan Sharma, AOR

For Respondent(s) : Mr. Varun Bedi, Adv. Ms. Swati Ahalawat, Adv. Mr. Akash Luthra, Adv. Mr. Rameshwar Prasad Goyal, AOR Mrs. Sudha Gupta, AOR Mr. Mohit Girdhar, Adv.