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Issues: Whether criminal proceedings for serious non-compoundable offences, particularly offences under Section 307 of the Indian Penal Code, 1860 and allied provisions, could be quashed under Section 482 of the Code of Criminal Procedure, 1973 merely because the parties had settled the dispute.
Analysis: The inherent power under Section 482 of the Code of Criminal Procedure, 1973 is distinct from the power to compound offences under Section 320 of that Code and must be exercised sparingly, with due regard to the nature and gravity of the offence. Heinous and serious offences having a societal impact, including attempt to murder and similar firearm-related offences, are not ordinarily fit for quashing on compromise alone. The Court reiterated that in such matters the High Court must consider the gravity of the allegations, the medical and other supporting material, the stage of investigation or trial, the conduct and antecedents of the accused, and whether the incorporation of Section 307 of the Indian Penal Code, 1860 is genuine and supported by evidence. Mechanical quashing merely because a compromise has been reached is impermissible where the offence is against society and not merely a private wrong.
Conclusion: The High Court erred in quashing the proceedings on the basis of compromise, and the quashing orders were set aside.
Final Conclusion: Criminal proceedings for serious offences of the kind alleged could not be terminated solely on the basis of settlement, and the matters were directed to proceed in accordance with law.
Ratio Decidendi: The inherent power to quash may be used on compromise only in cases having a predominantly private or civil flavour, not in serious offences affecting society unless the record shows that the accusation is unsupported and the possibility of conviction is truly remote.