Inherent quashing power under Section 482 CrPC may extend to settled matrimonial disputes despite non-compoundable offences.

The High Court's inherent power under Section 482 CrPC, read with Articles 226 and 227, can be used to quash FIRs or criminal proceedings where continuation would amount to abuse of process or fail to secure the ends of justice. A bar on compounding under Section 320 CrPC does not, by itself, limit that power. In matrimonial disputes, especially where the spouses have genuinely settled their differences and the prospect of conviction is remote, quashing may be appropriate even for non-compoundable offences such as Sections 498A and 406 IPC. Genuine settlements in such cases should be encouraged, and a rigid insistence on non-compoundability may defeat justice.

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Issues: Whether the High Court can exercise inherent powers under Section 482 of the Code of Criminal Procedure, 1973 read with Articles 226 and 227 of the Constitution of India to quash criminal proceedings or an FIR involving non-compoundable offences under Sections 498A and 406 of the Indian Penal Code, 1860 when the dispute is matrimonial and the parties have settled the matter.

Analysis: The inherent power preserved by Section 482 is intended to prevent abuse of the process of any court and to secure the ends of justice. The illustrative categories stated in prior decisions are not exhaustive, and the power is not controlled by a rigid formula. A bar on compounding under Section 320 of the Code of Criminal Procedure, 1973 does not, by itself, exclude the High Court's power to quash proceedings where the facts justify such relief. The reasoning in earlier authorities on revisionary limitations did not lay down any general restriction on quashing powers. In matrimonial disputes, particularly where the wife and husband have settled their differences and the prospects of conviction become remote, continuation of the prosecution may serve no useful purpose. Genuine settlements in such matters ought to be encouraged, and a hyper-technical insistence on non-compoundability may defeat the object of justice.

Conclusion: The High Court can quash criminal proceedings, FIRs, or complaints in appropriate matrimonial cases despite the offences being non-compoundable, and Section 320 of the Code of Criminal Procedure, 1973 does not limit or affect the power under Section 482.

Ratio Decidendi: The inherent jurisdiction to quash exists independently of the statutory scheme of compounding and may be exercised where continuance of prosecution would amount to abuse of process or would not secure the ends of justice, including in settled matrimonial disputes with bleak chances of conviction.

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