Inherent quashing after settlement can end private criminal proceedings even when a connected non-compoundable offence is alleged.

Where a private dispute has been fully settled and the complainant has received the agreed amount without protest, the High Court may exercise its inherent jurisdiction to quash the FIR and consequential proceedings if continuation would serve no useful purpose and the settlement advances the ends of justice. The presence of a connected non-compoundable allegation, including under Section 174A of the Indian Penal Code, does not by itself prevent quashing where the overall controversy is personal in nature and the principal offence stands effectively resolved by compromise. On those facts, the FIR and all consequential criminal proceedings were quashed.

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Issues: Whether the FIR and consequential proceedings could be quashed under the inherent jurisdiction of the Court on the basis of settlement between the parties, including in respect of the allegation under Section 174A of the Indian Penal Code, 1860.

Analysis: The dispute had been settled and the complainant had received the full and final settlement amount without protest. The principal offence had been compounded in effect by the settlement, and the Court followed the settled principle that, where the controversy is personal in nature and continuation of proceedings would serve no useful purpose, inherent powers may be exercised to secure the ends of justice. The Court also relied on the view that the presence of a connected non-compoundable allegation does not by itself bar quashing where the overall circumstances justify termination of the proceedings.

Conclusion: The FIR and all consequential proceedings were quashed.

Final Conclusion: The criminal proceedings were brought to an end in view of the compromise, and the petition succeeded.

Ratio Decidendi: In appropriate cases, the inherent power to quash may be exercised to terminate proceedings arising from a settled private dispute, even where a connected non-compoundable offence is alleged, if such quashing advances the ends of justice.

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