Where Dispute is Personal and Peace is Restored, Law Must Not Be Dragged Further: Supreme Court Quashes FIR in Neighbourhood Quarrel

"Justice Shall Be a Casualty If Criminal Trial Proceeds Despite Compromise Between Parties", In a ruling that underscores the principle that criminal law should not be reduced to a tool for harassment in private disputes, the Supreme Court of India quashed an FIR arising from a petty neighbourhood quarrel, observing that "continuation of proceedings in a case where the parties have amicably settled their differences would serve no purpose and defeat the ends of justice."

Setting aside the order of the Allahabad High Court, which had declined to quash the FIR despite the compromise, the Bench of Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi emphatically ruled that “when the chances of conviction are bleak and the wrong is essentially personal, criminal proceedings must be brought to an end.”

The FIR, registered under Sections 191(2), 115(2), 352, 351(3), and 324(4) of the Bharatiya Nyaya Sanhita, 2023, pertained to an altercation between neighbours in Prayagraj, and included allegations of voluntarily causing hurt, criminal intimidation, and use of force—offences the Court held were "not heinous in nature, nor having any significant societal impact."

"High Court Failed to Apply Gian Singh Principles Where It Was Most Needed"

Noting that the High Court merely directed compliance with arrest guidelines under Section 41 and 41-A CrPC and the Arnesh Kumar ruling, the Supreme Court held this to be a missed opportunity to prevent abuse of process.

The Court observed:

“Since the present case is a case of altercation between neighbours and no other person is involved, in our considered view, the High Court ought to have dealt with the matter considering the Supreme Court’s judgment in the case of Gian Singh v. State of Punjab.”

In Gian Singh, the Supreme Court had categorically held that even non-compoundable offences can be quashed under Section 482 CrPC if the dispute is predominantly civil or private in nature, and its continuation would be an exercise in futility.

Quoting the landmark ruling, the Court recalled:

“Justice in the case demands that the dispute between the parties is put to an end and peace is restored; securing the ends of justice being the ultimate guiding factor.”

In the present case, the parties had reached an amicable compromise even before the charge sheet was filed, and this was not contested by the complainant’s counsel before the Supreme Court. Recognising this, the Court stated:

“In the above view of the matter, we are of the opinion that it will not be appropriate to continue with the criminal proceedings… and the FIR deserves to be quashed to secure the ends of justice.”

“Inherent Powers Under Section 482 CrPC Exist to Prevent Abuse of Process, and Must Be Exercised Where Justice Demands”

The Court clarified that Section 482 CrPC confers wide and unrestricted inherent powers upon the High Courts, but their use is guided by two paramount objectives—to secure the ends of justice and to prevent abuse of the process of law.

Referring again to Gian Singh, the Court emphasized:

“Certain offences overwhelmingly bear civil flavour... where the wrong is basically to the victim and the offender and the victim have settled all disputes between them amicably, the High Court may, within the framework of its inherent power, quash the criminal proceeding.”

It reiterated that the power is not curtailed by statutory limitations, but must be applied “with regard to the nature and gravity of the crime” and the “likelihood of conviction.”

In this case, the Court found no element of heinousness, nor any "serious or depraved conduct." It was, as the Court noted, a “minor neighbourhood altercation”, and “justice shall be a casualty if the parties are forced to undergo a trial, the outcome of which is already rendered meaningless by their mutual settlement.”

Supreme Court Quashes FIR and All Criminal Proceedings

Holding that the High Court had erred in not exercising its inherent powers, the Supreme Court allowed the appeal, set aside the High Court’s order, and quashed the FIR No. 152 of 2025 registered at Police Station Bahariya, Prayagraj, along with all proceedings arising therefrom.

The Court concluded:

“It will not be appropriate to continue with the criminal proceedings… to save the parties from participating in a trial whose result is known on account of the compromise held between the parties.”

The ruling sets a clear precedent reinforcing the role of compromise in criminal litigation arising from private disputes, and affirms that criminal courts should not be used to perpetuate personal vendettas once peace is voluntarily restored.

Date of Decision: 16 January 2026