Criminal Cases Cannot Be Quashed Solely on Compromise: Supreme Court Ruling on Madhya Pradesh Appeals

The Supreme Court of India recently delivered a significant judgment addressing the legality of quashing criminal cases solely based on compromise between the accused and the complainant. The ruling came in response to appeals filed by the State of Madhya Pradesh, challenging the decisions of the High Court of Madhya Pradesh, which had quashed criminal proceedings against the accused under Section 482 of the Criminal Procedure Code (CrPC). The Supreme Court clarified that serious criminal offenses, particularly those affecting society at large, cannot be dismissed merely because the parties have reached an amicable settlement.

Background of the Case

The appeals stemmed from two criminal cases involving offenses under the Indian Penal Code (IPC) and the Arms Act. The first case pertained to an attempted murder charge (Section 307 IPC) against the accused, Dhruv Gurjar, and others. The second case involved a robbery (Section 394 IPC) and violations under the Madhya Pradesh Dacoity and Violent Crimes Act (M.P.D.V.P.K. Act) and the Arms Act.

In both cases, the accused approached the Madhya Pradesh High Court, seeking quashing of the FIRs based on compromise with the complainants. The High Court granted relief under Section 482 CrPC, citing that there was no likelihood of conviction, and continued trial would serve no purpose.

Arguments by the State of Madhya Pradesh

The State of Madhya Pradesh, aggrieved by the High Court’s orders, approached the Supreme Court, arguing:

• That the High Court had mechanically quashed the criminal proceedings without considering the seriousness of the offenses.
• The offenses involved were not private disputes but crimes against society, impacting public order and justice.
• The High Court misinterpreted the Supreme Court’s ruling in Shiji @ Pappu v. Radhika (2011), where quashing was allowed due to the civil nature of the dispute.
• The prosecution could still prove the case through medical evidence, witness statements, and material evidence, even if the complainant turned hostile.

Respondents’ Counterarguments

The defense argued that the High Court was justified in exercising its inherent powers to quash the proceedings since the parties had settled their disputes amicably. They relied on previous Supreme Court rulings that allowed quashing in cases where there was no likelihood of conviction.

Supreme Court’s Observations

The Supreme Court examined the High Court’s orders and emphasized the following principles:

• Nature of Offense: The Court reiterated that heinous crimes, such as attempted murder and robbery, cannot be quashed merely on the basis of compromise as they have a severe impact on society.
• Role of Evidence: Even if the complainant does not support the case, the prosecution may still prove the guilt of the accused through independent evidence.
• Judicial Discretion: The power to quash cases under Section 482 CrPC must be exercised cautiously, considering the gravity of the offense and its implications on public interest.

The Court referred to its previous rulings, including Gian Singh v. State of Punjab (2012) and State of Madhya Pradesh v. Deepak (2014), affirming that non-compoundable offenses, particularly those affecting society, should not be quashed based on private settlements.

Key Excerpts from the Supreme Court’s Judgment

The Supreme Court made the following key observations:

“The High Court has quashed the respective FIRs mechanically and solely on the basis of the settlement/compromise between the complainant and the accused, without even considering the gravity and seriousness of the offenses alleged.”

“Such offenses will have a serious impact on the society at large. Where the accused are facing trial under Sections 307, 294 read with Section 34 IPC as well as Sections 25 and 27 of the Arms Act, they will have to necessarily face trial and demonstrate their innocence.”

“Quashing of criminal proceedings on the basis of a compromise is not permissible when the offenses alleged are against society and are non-compoundable under the law.”

Final Verdict

The Supreme Court allowed the appeals, set aside the High Court’s orders, and directed that the criminal proceedings against the accused should continue as per the law.

Conclusion

This judgment reaffirms the principle that serious criminal offenses cannot be treated as private disputes. The ruling ensures that crimes impacting society at large are duly prosecuted, preventing accused individuals from escaping legal consequences through private settlements. It sets a precedent that courts must carefully scrutinize the nature of offenses before exercising discretionary powers under Section 482 CrPC.

Petitioner Name: State of Madhya Pradesh.
Respondent Name: Dhruv Gurjar and others, Tinku Sharma and others.
Judgment By: Justice L. Nageswara Rao, Justice M. R. Shah.
Place Of Incident: Madhya Pradesh.
Judgment Date: 22-02-2019.

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