Compromise-based quashing unavailable where FIR alleges cheating, forgery and possible GST evasion affecting public interest.

Compromise did not justify quashing an FIR alleging cheating, forgery and possible GST evasion because the allegations were not confined to a purely private dispute. The police material indicated a complaint before GST authorities and suggested possible violations under the GST regime, bringing the matter within the category of economic or other serious offences affecting the State and public interest. The settled principles on compromise-based quashing apply mainly to disputes of overwhelmingly civil character, not to allegations of this nature. Accordingly, the petition to quash the FIR was declined on the basis that the proceedings could not be terminated merely because the parties had settled.

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Issues: Whether an FIR alleging cheating, forgery and possible GST evasion could be quashed in exercise of inherent powers on the basis of compromise between the parties.

Analysis: The compromise between the parties was not treated as sufficient by itself because the allegations were not confined to a purely private dispute. The FIR and the connected police material indicated a complaint before the GST authorities and allegations suggesting possible violations under the GST regime. The settled principles governing quashing on compromise permit interference in cases having overwhelmingly civil character, but not where the allegations disclose economic or other serious offences affecting the State or public interest. The presence of possible GST-related offences and the nature of the allegations took the matter outside the category of cases ordinarily fit for quashing on compromise.

Conclusion: The petition for quashing of the FIR was rightly declined, as the proceedings could not be terminated merely on the basis of compromise in view of the possible GST offence and the serious nature of the allegations.

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