Summary

Naushey Ali & Ors. vs. State of U.P.

Case Citation: 2025 INSC 182
Court: Supreme Court of India
Issue: Quashing of criminal proceedings under Section 307 IPC based on compromise.
Judgment: The Supreme Court held that while compounding under Section 320 CrPC is different from quashing, in cases where the accused and the victim have settled and prosecution is unlikely to succeed, quashing can be justified.

Summary :

This appeal arose from a criminal case registered in 1991 involving a dispute over irrigation water, leading to cross-FIRs. One FIR (No. 248/91) was filed by the appellants against the complainants, while a counter-FIR (No. 248-A/91) was later lodged by the complainants. The police initially filed a final report stating that the FIR against the appellants was a counterblast and lacked substance. However, the Magistrate summoned the accused for trial, leading to protracted litigation over three decades.

During this period, three of the original accused passed away. In 2022, after intervention from village elders, a compromise was reached between the parties. The appellants approached the High Court under Section 482 CrPC, seeking quashing of the case in light of the settlement. The High Court refused, holding that an offense under Section 307 IPC could not be compounded.

The Supreme Court overruled the High Court's decision, distinguishing between compounding (which is statutory) and quashing (which is discretionary). It reiterated that in cases where prosecution serves no meaningful purpose, courts may exercise their inherent powers to quash proceedings, provided the offense does not involve public interest concerns. The Court quashed the criminal proceedings, citing long delay, lack of public interest, and the amicable settlement between the parties.

Key Points:

• The case involved a 1991 dispute where counter-cases were filed, and a later settlement was reached.

• The Allahabad High Court refused to quash proceedings, citing the non-compoundable nature of Section 307 IPC.

• The Supreme Court set aside the High Court’s order, distinguishing quashing from compounding.

Analysis:
This judgment aligns with past precedents (Gian Singh v. State of Punjab) that allow quashing in non-compoundable cases if prosecution is unlikely to serve justice. It provides flexibility in long-pending cases where reconciliation has been achieved.