The Rajasthan High Court has declined to quash a criminal case arising from an FIR registered under Section 376 of the Indian Penal Code, despite a compromise being reached between the complainant and the accused. Justice Anoop Kumar Dhand passed the order on May 19, 2026, while hearing a petition filed by Shankar Lal Meena.
Background of the Case
The petitioner approached the High Court seeking cancellation of FIR No. 63/2024 registered at Jawahar Circle Police Station, Jaipur City (East). The plea stated that the allegations in the FIR were false and that the complainant had subsequently entered into a compromise and expressed her unwillingness to continue the proceedings.
Based on this settlement, the petitioner requested the court to quash the FIR and all related proceedings.
During the hearing, the court examined the legal principles governing the quashing of criminal proceedings on the basis of compromise. Justice Dhand referred to several Supreme Court judgments, including Gian Singh v. State of Punjab, Narinder Singh v. State of Punjab, and State of Madhya Pradesh v. Laxmi Narayan.
The bench observed that while High Courts possess inherent powers to quash criminal proceedings in appropriate cases, such powers must be exercised cautiously.
“The offences like murder, rape and dacoity cannot be fittingly quashed even though the victim and the accused have settled the dispute,”
the court noted while referring to Supreme Court precedents.
The court further observed that such offences are not purely private disputes and have a broader impact on society.
Decision
Rejecting the request for quashing, the High Court held that proceedings arising from the FIR could not be terminated merely because the parties had reached a compromise. The court also noted that the matter was still under investigation.
The court clarified that the complainant is free to make her statement before the investigating authorities, and the Investigating Officer may proceed in accordance with law after completing the investigation.
With these observations, the criminal miscellaneous petition was disposed of, along with all pending applications.
Case Details:
Case Title: Shankar Lal Meena v. State of Rajasthan & Anr.
Case Number: S.B. Criminal Miscellaneous Petition No. 1560/2024
Judge: Justice Anoop Kumar Dhand
Decision Date: May 19, 2026
