CRM-M-21311-2026 1 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 292 CRM-M-21311-2026 Date of Decision: 23.07.2026 ARVINDER DHULL AND ORS ....Petitioner(s) VERSUS STATE OF HARYANA AND ORS ....Respondent(s) CORAM : HON’BLE MR. JUSTICE ALOK JAIN Present : Mr. J.C. Malik, Advocate for the petitioners. Mr. Amish Sharma, AAG, Haryana. Mr. Ashok Arora, Advocate for respondents no.2. ALOK JAIN, J. (Oral) 1. The present petition is for quashing of the FIR No.0144 dated 27.05.2022, under Section 506 IPC (corresponding Section 352 BNS) and Section 3(1)(c)(r)(s) of SC/ST (Prevention of Atrocities) Act, 1989 registered at Police Station Civil Line Jind, District Jind, and all other subsequent proceedings arising therefrom on the basis of compromise deed dated 04.04.2026 (Annexure P-2). 2. Keeping in view the fact that the parties entered into a compromise, this Court vide order dated 07.05.2026 directed the parties to appear before the Illaqa Magistrate/trial Court for getting their statements recorded in that regard. Pursuant thereto, a report dated 26.05.2026 has been received from the Addl. District and Sessions Judge, Jind, stating that the compromise arrived at between the parties is voluntary and the same is without any pressure, coercion or undue influence. 3. Learned State counsel and learned counsel appearing on DEEPAK PATWAL 2026.07.27 10:28 I attest to the accuracy and integrity of this document CRM-M-21311-2026 2 behalf of respondent No.2 admit the factum of compromise and submit that they have no objection to quashing of the FIR on that basis. 4. Perusal of the aforesaid report establishes that the parties have amicably settled their dispute, and continuance of criminal prosecution in such a situation will be an exercise in futility, as the chances of ultimate conviction are bleak. The power under Section 482 Cr.P.C. can be exercised in such matters. It has been held by Supreme Court of India in cases Gian Singh v. State of Punjab and another 2012(10) SCC 303 and Narinder Singh and others v. State of Punjab and another 2014(6) SCC 406 that criminal cases having overwhelmingly civil character, particularly those arising out of commercial transactions or matrimonial relationships or family disputes, should be quashed when the parties have resolved their disputes among themselves in a bona fide manner. 5. Moreover, in the case of ‘Ramawatar vs. State of Madhya Pradesh’, AIR 2021 SC 5228, wherein it has been observed as follow: 15. Ordinarily, when dealing with offences arising out of special statutes such as the SC/ST Act, the Court will be extremely circumspect in its approach. The SC/ST Act has been specifically enacted to deter acts of indignity, humiliation and harassment against members of Scheduled Castes and Scheduled Tribes. The Act is also a recognition of the depressing reality that despite undertaking several measures, the Scheduled Castes/Scheduled Tribes continue to be subjected to various atrocities at the hands of upper−castes. The Courts have to be mindful of the fact that the Act has been enacted keeping in view the express constitutional safeguards enumerated in Articles 15, 17 and 21 of the Constitution, with a twin−fold objective of protecting the DEEPAK PATWAL 2026.07.27 10:28 I attest to the accuracy and integrity of this document CRM-M-21311-2026 3 members of these vulnerable communities as well as to provide relief and rehabilitation to the victims of caste−based atrocities. xxx xxx xxx xxx 16. On the other hand, where it appears to the Court that the offence in question, although covered under the SC/ST Act, is primarily private or civil in nature, or where the alleged offence has not been committed on account of the caste of the victim, or where the continuation of the legal proceedings would be an abuse of the process of law, the Court can exercise its powers to quash the proceedings. On similar lines, when considering a prayer for quashing on the basis of a compromise/settlement, if the Court is satisfied that the underlying objective of the Act would not be contravened or diminished even if the felony in question goes unpunished, the mere fact that the offence is covered under a ‘special statute’ would not refrain this Court or the High Court, from exercising their respective powers under Article 142 of the Constitution or Section 482 Cr.P.C. The aforesaid judgment of Hon’ble Supreme Court conclusively settles the legal position with respect to the exercise of the Court inherent jurisdiction to quash criminal proceedings or an FIR, even in cases involving offences under the provision of SC/ST Act, where the parties have amicably resolved their disputes through a compromise. However, while exercising such jurisdiction the Court must satisfy itself that the compromise is voluntary, genuine, and has been arrived at by the parties of their own free will without any coercion or undue influence. 6. Consequently, this petition is allowed. FIR No.0144 dated 27.05.2022, under Section 506 IPC (corresponding Section 352 BNS) and DEEPAK PATWAL 2026.07.27 10:28 I attest to the accuracy and integrity of this document CRM-M-21311-2026 4 Section 3(1)(c)(r)(s) of SC/ST (Prevention of Atrocities) Act, 1989 registered at Police Station Civil Line Jind, District Jind, and all consequential proceedings arising therefrom, are hereby quashed qua the petitioner(s), subject to payment of cost of Rs.25,000/- jointly to be deposited by petitioners and Rs.10,000/- to be deposited by respondent no.2, within one month from today in Nishkam Sewa Group (run by Punjab and Haryana High Court Lawyers at Chandigarh). (ALOK JAIN) 23.07.2026 JUDGE Deepak Patwal 1. Whether speaking/reasoned Yes/No 2. Whether reportable Yes/No DEEPAK PATWAL 2026.07.27 10:28 I attest to the accuracy and integrity of this document