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Supreme Court of India 2019-02-22 allowed

State of Madhya Pradesh vs Dhruv Gurjar and another

Bench: 2 — M.R. Shah

In Brief

Two criminal appeals challenged the High Court's decision to quash FIRs for attempted murder (Section 307 IPC), outraging public decency (Section 294 IPC), and Arms Act violations. The High Court had quashed the proceedings solely on the ground that the complainant and accused had reached a settlement. The Supreme Court held that the High Court erred in mechanically quashing these serious, non-compoundable offences. The Court reaffirmed that offences affecting public interest—such as attempted murder and Arms Act violations—cannot be quashed merely because parties have compromised. The High Court must scrutinise the entire facts, considering the gravity of offences, accused's antecedents, and timing of settlement. The appeals were allowed and the FIRs restored for continuation of proceedings.

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Criminal Procedure Section 482 CrPC Quashing of FIR Compromise and Settlement Non-compoundable Offences Inherent Powers Public Interest Sections 307 and 294 IPC Arms Act

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