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Supreme Court of India 2021-09-29 partly_allowed

Krishnappa & Ors vs The State of Madhya Pradesh

Bench: 2 — N.V. Ramana, Surya Kant

In Brief

The Supreme Court addressed whether criminal proceedings involving non-compoundable offences can be quashed based on compromise between an accused and victim. The Court held that a High Court's inherent powers under Section 482 CrPC (and the Supreme Court's plenary powers under Article 142) can be invoked to quash proceedings for non-compoundable offences when: (1) the offence is non-heinous and predominantly private in nature; (2) parties voluntarily settle; and (3) factors like injury severity and accused's conduct support quashing. Heinous offences like murder, rape, or those under anti-corruption laws cannot be quashed. The Court quashed proceedings in the first appeal based on settled compromise and directed the High Court to verify settlement in the second appeal before deciding.

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Criminal Procedure Compounding of Offences Non-compoundable Offences Inherent Powers of Court Settlement and Compromise Section 482 CrPC Article 142 Constitution Private Nature Offences Administration of Criminal Justice

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