The Supreme Court ruled that an informant's consent is not required when quashing a criminal case under Section 482 CrPC (now Section 528 BNSS) based on a settlement between the accused and the actual victim. The Court drew a clear distinction between the informant who lodges the FIR and the person who actually suffered the offence. Where the real victim has settled, the informant's objection cannot block quashing, as the victim's autonomy and the ends of justice prevail.

This ruling sharpens a critical distinction in quashing jurisprudence under Section 482 CrPC (Section 528 BNSS). Courts have inherent power to quash FIRs to secure the ends of justice, but this power is exercised carefully in cases involving serious versus compoundable offences.

The central principle here is: the informant and the victim are legally distinct persons. An informant is merely the person who sets the criminal law in motion by lodging an FIR — they need not be the one who suffered the harm. The victim is the person against whom the offence was actually committed. When these two roles vest in different people, it is the victim's consent to settlement that carries legal weight for quashing purposes, not the informant's.

The Court's reasoning flows from the purpose of criminal law itself. In primarily private disputes — matrimonial offences, cheating between individuals, hurt — the rationale for continuing prosecution weakens when the injured party has been made whole through settlement. The informant's refusal to consent in such cases is legally irrelevant because the informant has no independent stake in the injury.

This principle connects to the landmark ruling in Gian Singh v. State of Punjab (2012), where the Supreme Court laid down the framework for quashing FIRs in non-compoundable but essentially private offences. It also intersects with Section 320 CrPC (compounding of offences) — but quashing under Section 482 can go further, covering offences not listed under Section 320.

For CLAT PG, the examiner will test whether aspirants can correctly identify who qualifies as the 'victim' for quashing purposes and whether the informant's objection is a legal bar.