Supreme Court Quashes Criminal Proceedings Arising From Same Incident By Exercising Article 142

A bench of Justice B.V. Nagarathna and Justice Satish Chandra Sharma heard an appeal against the Allahabad High Court’s dismissal of a Section 482 CrPC application seeking quashing of the charge-sheet dated 15.01.2020 and the summoning order dated 14.11.2020 in Case Crime No.415/2019 (State v. Nadeem) arising out of Shahganj Police Station, Jaunpur. The challenge concerned allegations framed under Sections 307, 323, 324, 427, 447, 504 and 506 IPC and the scope of the Court’s power to quash non-compoundable offences when related compoundable offences stood settled between the parties.

The Court allowed the appeal and, exercising its extraordinary powers under Article 142 of the Constitution, quashed the criminal proceedings in Case Crime No.415/2019. The judges accepted the joint settlement between the parties and held that, as the offences arose from the same incident and several were compoundable under Section 320 CrPC, it would be appropriate to quash the remaining non-compoundable allegations as well. The petition filed under Article 142 by respondent no.2 seeking quashing was allowed and the impugned order was set aside. The Court recorded that "the parties do not wish to proceed against each other" and noted that respondent no.2 had expressed no objection to quashing the FIR and subsequent proceedings. The Court, in its reasoning, observed: "It is only one case, namely, Case Crime No.415/2019 which is now pending before the concerned Sessions Court. We also find that Sections 323, 504, 427, 447 and 506 of the IPC are compoundable offences as per Section 320 of the CrPC. We find that the chargesheet may have also been filed under Sections 307 and 324 of the IPC which are non-compoundable offences. But having regard to the fact that these offences arise from the same incident and certain of these offences are now being compounded having regard to the prayers made by the respective parties, we find that in exercise of our powers under Article 142 of the Constitution of India, the offences alleged against the appellant herein under Sections 307 and 324 IPC shall also be quashed as the other offences alleged against the appellant herein are compoundable under Section 320 of the CrPC."

Background The dispute arose from an FIR registered as Case Crime No.415/2019 under multiple sections of the IPC, following alleged violence and related acts at Shahganj, Jaunpur. The appellant sought quashing of the charge-sheet and summoning order by invoking Section 482 CrPC; the Allahabad High Court dismissed that plea on 14.10.2022, prompting the present appeal. During the pendency of the appeal before this Court, the parties executed a settlement agreement (dated 03.02.2025) and asserted that they “do not wish to proceed against each other” and intended to continue as landlord and tenant, with respondent no.2 agreeing to remain a tenant on payment of rent. Respondent no.2 filed an application under Article 142 of the Constitution, supported by affidavits and documentary records of related civil suits and earlier compounding in another criminal case (Case Crime No.416/2019) where proceedings had been compounded.

The Supreme Court examined the paperwork and noted that several of the charged offences (Sections 323, 504, 427, 447 and 506 IPC) were explicitly compoundable under Section 320 CrPC. Finding that the offences arose out of a single incident and that settlement had been entered into voluntarily by the parties, the Court exercised its constitutional powers to extend the effect of compounding to the non-compoundable counts (Sections 307 and 324) so as to secure complete justice between the parties. The appeal was allowed and the proceedings in Case Crime No.415/2019 were quashed; the impugned High Court order was set aside and pending applications were disposed of. No interim directions were recorded other than the acceptance of the settlement; the Court did not indicate any broader precedent overruling but relied on the scope of Article 142 in the facts of the case.

Case Details: Case No.: 2025 INSC 659 (Criminal Appeal @ SLP (Crl.) No.12088 of 2022) Case Title: Nadeem Ahmad v. The State of U.P. & Anr. Appearances: For the Petitioner(s): Counsel for appellant (name not recorded in order) For the Respondent(s): Standing Counsel for State (name not recorded); Counsel for respondent no.2 (name not recorded)