Amicable settlement can justify quashing criminal proceedings and secure consequential relief, including return of a passport.

Where parties amicably settle their dispute and place the compromise on record, the Court may treat the settlement as the basis for ending pending criminal litigation and grant consequential relief. Here, the compromise covered FIRs for alleged IPC offences and complaint cases under section 138 of the Negotiable Instruments Act, so the criminal proceedings were quashed. The return of the passport followed as a direct consequential direction in favour of the appellant.

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Issues: Whether, in view of the compromise between the parties, the criminal proceedings arising out of the FIRs and complaint cases were liable to be quashed, and whether consequential relief could be granted.

Analysis: The parties placed a settlement on record and undertook to abide by its terms. On that basis, the Court accepted the compromise as forming part of the order and treated it as the foundation for ending the pending criminal litigation between the parties. The quashing covered the FIRs registered for the alleged offences under the Indian Penal Code and the complaints under section 138 of the Negotiable Instruments Act, 1881. The return of the passport followed as a direct consequence of the quashing.

Conclusion: The criminal proceedings were quashed and the consequential direction for return of the passport was issued in favour of the appellant.

Ratio Decidendi: Where the parties have amicably settled their dispute and the settlement covers the pending criminal proceedings, the Court may quash the proceedings and grant consequential relief.

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