K.Subramani v. State Of Tamilnadu Rep By The Sub Inspector Of Police, Mattuthavani
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT Dated : 27/02/2026
CORAM
THE HONOURABLE MRS. JUSTICE L. VICTORIA GOWRI K.Subramani ... Petitioner Vs
1. State of Tamilnadu Rep by The Sub Inspector of Police, Mattuthavani Police Station, Madurai District.
(Crime No.667/2025).
2. Rathna ... Respondents PRAYER :- To calling for the records and quash the FIR in Crime No.667/2025, on the file of Sub Inspector of Police, Mattuthavani Police Station, as against the petitioner/Accused.
For Petitioner : Mr. M.Mathankarthick, Advocate.
For Respondent : Mr.M.Sakthi Kumar for R1 Government Advocate (Crl.Side) Ms. Aishwarya Caroline for R2 1/7
ORDER
This Criminal Original Petition is filed under Section 482 CrPC / Section 528 BNSS, seeking to quash the FIR in Crime No.667 of 2025 on the file of the 1st respondent.
2. The gist of the allegations in the FIR is that the due to previous enmity, the accused person abused the defacto complainant in filthy language and attacked her. Pursuant to the complaint given by the defacto complainant / second respondent, a case in Crime No.667 of 2025 was registered on the file of the first respondent against the petitioner for the offences under Sections 296(b), 115(2) of BNS, 2023. Seeking quashment of the FIR, this Criminal Original Petition is filed. 3.
Admittedly, the petitioner and the second respondent are known to each other, and they have now resolved the dispute amicably. A Joint Compromise Memo dated 13.02.2026 has been filed before this Court.
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4.
The petitioner and the second respondent / defacto complainant are present before this Court in person and are identified by Mr.P.Muniyandi, SSI, Mattuthavani Police Station, Madurai District. The defacto complainant has categorically stated that he does not wish to pursue the proceedings against the petitioner herein. 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 2012 (10) SCC 303 3/7
impact on society, holding that the latter category cannot ordinarily be quashed merely on the basis of a settlement.
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 2017 (9) SCC 641 2019 (5) SCC 688 4/7
examining compromise quash petitions, the High Court must consider the nature and gravity of the offence, the conduct of the accused, and the 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. 5/7
10.
Accordingly, the impugned FIR in Crime No.667 of 2025 on the file of the first respondent is quashed and the Criminal Original Petition stands allowed. The joint compromise memo dated 13.02.2026 shall form part and parcel of this order.
27.02.2026 NCC : yes / no Index : yes / no Internet : yes no pnn To
1. The Sub Inspector of Police, Mattuthavani Police Station, Madurai District. (Crime No.667/2025).
2. The Additional Public Prosecutor, Madurai Bench of Madras High Court, Madurai.
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L. VICTORIA GOWRI,J pnn
ORDER
IN CRL OP(MD) No.3145 of 2026 Date : 27/02/2026 7/7