Manikandan @ Balasubramanian v. State Of Tamilnadu Rep By Inspector Of Police, Lalgudi
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT Dated : 20/01/2026
CORAM
THE HONOURABLE MRS. JUSTICE L.VICTORIA GOWRI CRL OP(MD). No.847 of 2026 Manikandan @ Balasubramanian ... Petitioner Vs 1.State of Tamilnadu Rep by Inspector of Police, Lalgudi Police Station Lalgudi, Trichy, in Crime No.355 of 2024 2.Muruganatham ... Respondents PRAYER :- To call for the records pertaining to the FIR in Crime No.355 of 2024 on the file of the first respondent police and quash the same as illegal.
For Petitioner : Mr. B.Karthikeyan Advocate.
For Respondents : Mr.B.Thanga Aravindh for R1 Government Advocate (Crl.Side) M/s.K.Ramkumar for R2 1/8
CRL OP(MD). No.848 of 2026 1.Vinothkannan 2.Muruganatham ... Petitioners Vs 1.State of Tamilnadu Rep by Inspector of Police, Lalgudi Police Station Lalgudi, Trichy, in Crime No.356 of 2024 2.Manikandan @ Balasubramanian ... Respondents PRAYER :- To call for the records pertaining to the FIR in Crime No.355 of 2024 on the file of the first respondent police and quash the same as illegal.
For Petitioner : Mr. K.Ramkumar Advocate.
For Respondents : Mr.B.Thanga Aravindh for R1 Government Advocate (Crl.Side) M/s.B.Karthikeyan for R2
ORDER
This Criminal Original Petition is filed under Section 528 of BNSS, seeking to call for the records pertaining to the FIR in Crime Nos. 2/8
355 and 356 of 2024 on the file of the first respondent police and quash the same as illegal, in so far as the petitioner is concerned.
2. The gist of the allegations in the final report is that on 23.07.2024, the 2nd respondent lodged a complaint before the first respondent stating that on 21.07.2024, the petitioner brought people and organized cockfights. When the same was questioned by the defacto complainant / 2nd respondent, the petitioner scolded the defacto complainant and his son which resulted into wordy quarrel. On the complaint given by both the petitioner and the second respondent, a case and a counter case in Crime Nos.355 and 356 of 2024 were registered for the offences under Sections 296(b), 18(1), 351(3) of the BNS, 2023.
3. Admittedly, the petitioner and the second respondent in both the cases, are known to each other and residing in the same locality and they have now resolved the dispute amicably. A Joint Compromise Memo dated 19.01.2026 has been filed before this Court. 3/8
4. The petitioner and the second respondent are present before this Court in person and are identified by Mr.A.Silambuselvi, Women Head Constable, Lalgudi Police Station, Trichy District. The defacto complainant has categorically stated that he does not wish to pursue the FIR against the petitioner. This Court is satisfied that the compromise is voluntary and not the result of any coercion or undue influence. 5.
The law relating to quashment of criminal proceedings on the basis of compromise between the parties is well settled. In Gian Singh v. State of Punjab1, the Hon'ble Supreme Court authoritatively held that the inherent power of the High Court under Section 482 CrPC is of wide amplitude and may be exercised to quash criminal proceedings even in respect of non-compoundable offences, provided the dispute is essentially private in nature and the quashment would secure the ends of justice. The Court, however, drew a clear distinction between offences arising out of personal or matrimonial disputes, commercial transactions and similar private wrongs, and serious or heinous offences having grave impact on society, holding that the latter category cannot ordinarily be quashed merely on the basis of a settlement.
2012 (10) SCC 303 4/8
6.
The said principles were succinctly crystallised in Parbatbhai Aahir v. State of Gujarat2, wherein the Supreme Court, after surveying the earlier precedents, laid down broad propositions governing the exercise of inherent jurisdiction on the basis of compromise. It was emphasised that the paramount consideration is whether the continuance of the criminal proceedings would be unfair or contrary to the interests of justice, and whether the dispute predominantly bears a civil or private character, rendering the possibility of conviction remote and bleak. 7.
In State of Madhya Pradesh v. Laxmi Narayan3, the Supreme Court reiterated and clarified the limitations on such power, holding that offences of a serious nature, particularly those involving mental depravity, grave violence, or offences against society at large, cannot be quashed on the basis of compromise, even if the parties have amicably settled the dispute. The Court further cautioned that while examining compromise quash petitions, the High Court must consider the nature and gravity of the offence, the conduct of the accused, and the 2017 (9) SCC 641 2019 (5) SCC 688 5/8
stage of the proceedings, and the overall impact on society and must satisfy itself that the settlement is voluntary and not the result of coercion or undue influence.
8. Applying the aforesaid principles to the facts of the present case, this Court has carefully examined the nature and gravity of the allegations, the relationship between the parties, the conduct of the petitioner, the stage of the proceedings, and the voluntary nature of the compromise.
9. The dispute in question is predominantly private in character and does not involve any offence having serious or grave impact on society at large. In view of the compromise arrived at between the parties, the possibility of conviction is rendered remote and bleak. Continuation of the criminal proceedings would therefore serve no useful purpose and would amount to an abuse of the process of Court.
10. Accordingly, the impugned FIR in Crime Nos.355 and 356 of 2024 on the file of the first respondent police, is quashed in entirety and 6/8
these Criminal Original Petitions stand allowed. The petitioners shall deposit a sum of Rs.2500/-(Rupees Five Thousand only) to the District Legal Service Authorities, Trichy District, within a period of one week from today. The joint compromise memo dated 19.01.2026 shall form part and parcel of this order.
11. The petitioner is directed to file a memo along with the photocopy of the receipt before the Registry on or before 13.02.2026. List the matter on 18.02.2026, for reporting compliance. 20.01.2026 NCC : yes /no Index : yes / no Internet : yes / no pnn To 1.The Inspector of Police, Lalgudi Police Station Lalgudi, Trichy, in Crime Nos.355 and 356 of 2024.
2. The Additional Public Prosecutor, Madurai Bench of Madras High Court, Madurai.
7/8
L.VICTORIA GOWRI,J pnn
ORDER
IN Date : 20/01/2026 8/8