Quashing non-compoundable criminal proceedings after compromise may be justified where the dispute is private and abuse of process would continue.

A High Court may, in appropriate cases, use its inherent jurisdiction under Section 482 CrPC or writ jurisdiction under Article 226 to quash FIRs and criminal proceedings even for non-compoundable offences when the dispute is essentially private and the parties have settled. Section 320 CrPC governs compounding, but it does not exhaust the court's power to prevent abuse of process and secure the ends of justice. Where continuation of prosecution would serve no useful purpose, quashing may be justified. On the stated facts, the compromise between the parties supported termination of the proceedings.

---

---

Issues: Whether a First Information Report and the resulting criminal proceedings for offences that are not compoundable can be quashed under Section 482 of the Code of Criminal Procedure, 1973 or Article 226 of the Constitution of India when the parties have compromised and settled the dispute.

Analysis: The power to quash criminal proceedings is distinct from the power to compound offences. Section 320 of the Code of Criminal Procedure, 1973 governs compounding, but it does not exhaust the High Court's inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 or its writ jurisdiction under Article 226 of the Constitution of India. That jurisdiction is discretionary and must be exercised to prevent abuse of process and to secure the ends of justice, depending on the facts of each case. On the facts, the dispute was of a private nature, the complainant had settled the matter, and continuation of the proceedings would serve no useful purpose.

Conclusion: The criminal proceedings and the FIR were liable to be quashed notwithstanding that some of the offences were non-compoundable, and the appeal succeeded.

Final Conclusion: The High Court's refusal to quash the proceedings was set aside, and the prosecution was terminated in view of the compromise between the parties.

Ratio Decidendi: The High Court may, in appropriate cases, exercise its inherent or writ jurisdiction to quash criminal proceedings involving non-compoundable offences where the dispute is essentially private and continuation of the prosecution would amount to abuse of process and frustrate the ends of justice.

---