Allahabad High Court Quashes Criminal Proceedings in SC/ST Act Case Following Voluntary Compromise

Court exercises powers to quash proceedings, ensuring compromise was free from coercion and undue influence.

In a landmark decision, the Allahabad High Court has quashed criminal proceedings against Rahul Gupta and six others in a case under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, following a voluntary compromise between the parties involved. The judgment was delivered by Justice Shekhar Kumar Yadav on November 4, 2025.

The case, arising from Case Crime No.0126 of 2024, involved charges under various sections of the Indian Penal Code, including sections 147, 323, 500, 504, and 506, alongside Section 3(2)(va) of the SC/ST Act. The proceedings were pending before the Special Judge, SC/ST Act, Meerut, and have now been quashed based on the verified compromise between the parties.

The appellants, represented by counsel Dhiraj Kumar and Romeshwari Prasad, argued that the compromise was entered into voluntarily, without any coercion or undue influence, and was a result of free will and consent from the parties. The court verified the compromise, ensuring that it adhered to the principles laid out in previous judgments, including Ramawatar v. State of M.P. (2022) and Ghulam Rasool Khan v. State of U.P. (2022).

Justice Yadav noted that the case involved a purely private dispute and that the alleged offence was not committed on account of the caste of the victim. The court emphasized the importance of ensuring that compromises in cases involving SC/ST victims are entered into voluntarily, given the vulnerability of these communities to coercion.

The court's decision underscores the judiciary's role in safeguarding the rights of vulnerable groups while also acknowledging the resolution of disputes through mutual consent. The judgment reflects the court's commitment to preventing the abuse of legal processes in cases where the underlying offence is of a private nature.

The judgment also directed the opposite party to return the compensation amount received from the concerned authority within a week, further ensuring compliance with the terms of the compromise.

This decision highlights the discretionary powers of the High Court under Section 482 of the Criminal Procedure Code to quash proceedings in light of a verified compromise, promoting a balanced approach to justice where legal proceedings may otherwise continue unnecessarily.

Bottom Line:

Criminal proceedings under the SC/ST Act can be quashed if the alleged offence is of a private nature, not committed on account of caste, and a compromise is entered into voluntarily by the parties without coercion or undue influence.

Statutory provision(s): Scheduled Castes and The Scheduled Tribes (Prevention of Atrocities) Act, 1989 Sections 3(2)(va), Criminal Procedure Code, 1973 Section 482, Indian Penal Code Sections 147, 323, 500, 504, 506.

Rahul Gupta v. State of U.P., (Allahabad) : Law Finder Doc Id # 2812445