Article 142 relief in personal disputes can set aside conviction after a genuine compromise between close relatives.

A voluntary compromise in a personal dispute between close relatives may justify relief under Article 142 where the offence has limited societal impact. Sections 323 and 325 IPC are compoundable, but Section 324 IPC is non-compoundable, so compromise alone cannot permit compounding of that offence. The Court nevertheless may exercise its extraordinary powers in an appropriate case, taking into account the genuineness of the settlement, the relationship between the parties, the nature of the injuries, and the overall circumstances. On those facts, the compromise was accepted as genuine and the conviction was set aside.

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Issues: Whether the conviction for offences under Sections 323, 324 and 325 read with Section 34 of the Indian Penal Code could be set aside on the basis of a compromise between close relatives, in the exercise of powers under Article 142 of the Constitution.

Analysis: The offences under Sections 323 and 325 are compoundable, while Section 324 is non-compoundable. A compromise by itself does not permit compounding of a non-compoundable offence, but the extraordinary power under Article 142 may be exercised in appropriate cases, particularly where the dispute is personal, the parties are closely related, the compromise is voluntary, and the offence has limited societal impact. The nature of the injuries, the relationship between the parties, and the overall circumstances are relevant in deciding whether the case is fit for such relief.

Conclusion: The compromise was accepted as genuine and the case was held fit for exercise of powers under Article 142. The conviction of the appellants was set aside.

Ratio Decidendi: In an appropriate case involving a voluntary compromise in a personal dispute with limited societal impact, the Supreme Court may invoke Article 142 to set aside a conviction even where one of the offences is non-compoundable.

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