The position that emerges from the above discussion can be summarised thus:
The High Court’s inherent power to quash a criminal proceeding, FIR, or complaint is distinct and distinct from the power granted to a criminal court to compound offences under Section 320 of the Code. While inherent power has no statutory limitations, it must be exercised in accordance with the guidelines engrafted in it, namely to secure the ends of justice or to avoid abuse of any court’s procedure. Where the accused and the victim have resolved their dispute, the power to quash the criminal proceeding, complaint, or FIR may be exercised depending on the facts and circumstances of each case.
However, before exercising this authority, the High Court must consider the nature and gravity of the offence. Even if the victim or victim’s family has resolved the matter with the offender, heinous and grave offences of mental depravity, such as murder, rape, or dacoity, cannot be lawfully quashed. These are not private offences and have a significant influence on society.
Similarly, any agreement reached between the victim and the offender regarding offences punishable under special statutes such as the Prevention of Corruption Act or offences committed by public servants while performing their official duties, etc., cannot serve as a basis for the dismissal of criminal proceedings involving such offences. However, criminal cases with an overwhelmingly and predominatingly civil naure stand on a different footing for the purposes of quashing, particularly those arising out of commercial, financial, mercantile, civil, partnership, or similar transactions, or those arising out of matrimonial disputes involving dowry, etc., or family disputes in which the wrong is essentially private or personal in nature and the parties have resolved their entire dispute. The High Court may quash criminal proceedings in this category if, in its opinion, the possibility of conviction is remote and bleak as a result of the offender’s compromise with the victim, and the continuation of the criminal case would subject the accused to severe oppression and prejudice, as well as extreme injustice, by not quashing the criminal case despite full and complete settlement and compromise with the victim.
In other words, the High Court must consider whether continuing the criminal proceeding would be unjust or contrary to the interests of justice, whether continuing the criminal proceeding would constitute an abuse of process of law despite settlement and compromise between the victim and the wrongdoer, and whether, to secure the ends of justice, it is appropriate to end the criminal case.