Inherent powers can quash cheque dishonour proceedings after conviction when a genuine private compromise serves the ends of justice.

The High Court may exercise inherent power under Section 482 CrPC to quash a cheque dishonour prosecution, including the complaint, conviction and sentence, even after conviction during pendency of appeal, where the dispute is essentially private and the compromise is genuine, voluntary and comprehensive. A settled financial dispute under Section 138 of the Negotiable Instruments Act, with no grave public wrong or societal injury, can be brought to an end if quashing serves the ends of justice and does not affect public interest. On that basis, the complaint, conviction, sentence, arrest warrant and subsequent proceedings were quashed subject to deposit of the stipulated amount within the time granted.

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Issues: Whether the criminal complaint, conviction, sentence and consequential proceedings under Section 138 of the Negotiable Instruments Act, 1881 could be quashed under Section 482 of the Code of Criminal Procedure, 1973 on the basis of a genuine compromise arrived at during the pendency of the appeal after conviction.

Analysis: The compromise was treated as voluntary, genuine and comprehensive, with the monetary dispute having been settled between the parties. The offence arose out of a private financial transaction and did not involve any element of grave public wrong or injury to society. Relying on the settled scope of inherent jurisdiction, the Court held that post-conviction compromise can justify quashing where it serves the ends of justice and does not undermine public interest. The Court also noticed the settlement stage and the principles governing compromise in cheque dishonour matters.

Conclusion: The complaint, conviction, sentence, arrest warrant and all subsequent proceedings were quashed and set aside in favour of the petitioner, subject to deposit of the stipulated amount within the time granted.

Final Conclusion: The petition was allowed on the basis of compromise, bringing the criminal prosecution to an end while recognising the High Court's power to terminate private criminal disputes even after conviction, where justice so requires.

Ratio Decidendi: The High Court may exercise its inherent power to quash criminal proceedings, including after conviction during pendency of appeal, where the dispute is essentially private, the compromise is genuine and voluntary, and quashing secures the ends of justice without adverse societal impact.

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