The Supreme Court has held that a post-conviction compromise between parties can be used to quash criminal proceedings in non-heinous offences under Section 482 CrPC (Section 528 BNSS). The Court distinguished between offences that are purely private in nature and those that have a significant societal impact. Where the dispute is personal and the parties have genuinely settled, the conviction and sentence can be set aside even after trial concludes, provided the offence is not grave or heinous.

This ruling expands the practical scope of Section 482 CrPC (inherent powers of the High Court) and its BNSS equivalent, Section 528. Courts have long permitted quashing of FIRs and charge-sheets before or during trial based on compromise in compoundable and even some non-compoundable offences (following Gian Singh v. State of Punjab, 2012). The critical doctrinal question was always: does this power survive a conviction? The answer was historically ambiguous.

The Supreme Court now clarifies that the stage of proceedings — including post-conviction — does not automatically bar the exercise of inherent powers, provided the offence falls in the non-heinous category. The key analytical test is not compoundability under Section 320 CrPC alone, but the nature of the offence: does it primarily affect the victim-complainant, or does it wound public interest so deeply that no private settlement can undo the social harm?

This distinction, first systematised in Narinder Singh v. State of Punjab (2014) and reinforced in Parbatbhai Aahir v. State of Gujarat (2017), creates a two-track approach. Offences like murder, rape, dacoity, and crimes against the State are categorically excluded. Minor assault, simple hurt, cheating between known parties, and matrimonial disputes sit at the other end where compromise-based quashing survives even a conviction.

For CLAT PG aspirants, the statutory architecture matters: Section 320 CrPC lists compoundable offences; Section 482 CrPC grants inherent powers; and the Supreme Court's supervisory jurisdiction under Article 136 or writ jurisdiction under Article 226 operate as parallel routes. The BNSS equivalents are Sections 359, 528, respectively.