Inherent quashing of criminal proceedings after genuine compromise can extend to non-compoundable offences in private disputes.

Criminal proceedings arising from allegations of cheating, criminal breach of trust and criminal intimidation in a promised employment dispute may be quashed under the inherent jurisdiction when the parties have genuinely settled the matter. The victims filed affidavits and appeared before the Court confirming compromise and stating that they had no objection to quashing. The Court treated the allegations against some accused as general in nature and found that continuation of the prosecution would serve no useful purpose after settlement, even though the offences were non-compoundable. On that basis, the proceedings were quashed under Section 482 of the Code of Criminal Procedure, 1973.

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Issues: Whether the criminal proceedings could be quashed under Section 482 of the Code of Criminal Procedure, 1973 on the basis of compromise between the accused and the victims in respect of non-compoundable offences.

Analysis: The dispute arose from allegations of cheating, criminal breach of trust and criminal intimidation connected with promised employment. The victims filed affidavits and appeared before the Court confirming that the dispute had been amicably settled and that they had no objection to quashing. The Court also noted that the allegations against some accused were general in nature and that continuing the trial would serve no useful purpose after the settlement. Relying on the principles governing exercise of inherent jurisdiction in settled disputes, the Court held that the compromise could be taken into account notwithstanding the non-compoundable nature of the offences.

Conclusion: The proceedings were quashed in exercise of inherent jurisdiction, and the petition was allowed.

Ratio Decidendi: In a case involving predominantly private disputes, criminal proceedings may be quashed under Section 482 of the Code of Criminal Procedure, 1973 when the parties have genuinely settled the matter and continuation of the prosecution would serve no useful purpose, even if the offences are non-compoundable.

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