Supreme Court allows FIR quashing after parties settle dispute.

The Supreme Court has held that where parties have voluntarily settled a dispute that is essentially private in nature, the high court can exercise its extraordinary powers to quash the criminal proceedings instead of relegating the parties to the trial court for compounding the offences.

A Bench of Justices Sandeep Mehta and Devendra Kumar Upadhyaya made the observation while quashing an FIR after noting that the compromise between the parties had been duly verified by the Registrar of the high court.

Court found that there was no reason to direct the parties to approach the trial court for compounding when the complainant had categorically stated that the dispute had been settled and the matter was purely private in nature.

Court was dealing with an appeal filed by one Abhishek Dutt against an August 21, 2026 order passed by a single judge bench of the Madhya Pradesh High Court, Bench at Gwalior.

The high court had dismissed Dutt's petition, along with that of proforma respondent no. 3, seeking quashing of a 2022 FIR registered at Police Station Padav, Gwalior, for offences under Sections 420 and 34 of the Indian Penal Code, 1860 [Section 318(4) and Section 3(5) of the BNS, respectively].

The FIR had been lodged on the complaint of respondent no. 2, Dr Amarjit Singh Bhalla.

During the proceedings before the high court, Dutt and the complainant sought quashing of the FIR on the basis of a compromise. The parties filed applications supported by their affidavits, stating that the dispute had been settled.

The compromise was subsequently verified by the Registrar of the high court. The high court also recorded that the parties had voluntarily entered into the settlement without any threat, inducement or coercion.

Despite this, the high court declined to quash the proceedings. It held that since the offences were compoundable, the parties could approach the trial court by filing an application for compounding.

The Supreme Court, however, disagreed with this approach.

It noted that both before the high court and the Supreme Court, the complainant had categorically stated that the dispute had been settled and that the FIR should be quashed.

Court further found that the dispute was "purely private" and arose out of a monetary transaction.

"In this background, we are of the view that there was no reason whatsoever for the high court to have relegated the parties to the trial court for moving an application for compounding of the offences," the Bench said.

Court held that the high court's decision to reject the quashing petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) [earlier Section 482 CrPC] and direct the parties to approach the trial court was not justified, particularly when the settlement had already been verified by the Registrar.

The Bench relied on the Supreme Court's judgment in Gian Singh v. State of Punjab & Anr. (2012), which deals with the exercise of inherent powers to quash criminal proceedings following a settlement between the parties.

"Once, the high court itself recorded the fact that the parties had voluntarily arrived at a compromise, it was a fit case for exercise of extraordinary powers of the court to quash the proceedings," the Bench said.

Court accordingly allowed the appeal and quashed the FIR as well as all criminal proceedings arising from it.

Case Title: Abhishek Dutt Vs State of Madhya Pradesh & Ors

Bench: Justices Sandeep Mehta and Devendra Kumar Upadhyaya 

Date of Order: October 13, 2026

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