Court emphasizes the societal impact of heinous crimes, ruling out compromise as a basis for quashing proceedings.
In a significant ruling, the Rajasthan High Court has refused to quash an FIR pertaining to a rape allegation against Shankar Lal Meena, despite a compromise reached between the prosecutrix and the accused. The judgment, delivered by Justice Anoop Kumar Dhand at the Jaipur Bench, underscores the distinction between private disputes and crimes that have a broader societal impact.
The case in question arose from FIR No. 63/2024, registered at the Jawahar Circle Police Station in Jaipur, under Section 376 of the Indian Penal Code (IPC), which pertains to rape. The petitioner, Shankar Lal Meena, had sought the quashing of the FIR on the grounds that the prosecutrix had agreed to a compromise and expressed her unwillingness to pursue the charges.
However, the court, in its ruling dated May 19, 2026, highlighted that the power to quash criminal proceedings under Section 482 of the Criminal Procedure Code (CrPC) is distinct from the power to compound offences under Section 320 of the CrPC. The court emphasized that heinous crimes like rape, which have severe societal implications, cannot be quashed merely due to a private settlement between the involved parties.
The judgment referenced several Supreme Court decisions, including Gian Singh v. State of Punjab, Narinder Singh v. State of Punjab, and State of M.P. v. Laxmi Narayan, which collectively affirm that crimes of a grave nature, such as rape, murder, and dacoity, are not private disputes and have a significant impact on society. Consequently, such offences should not be quashed even if a compromise is reached.
Justice Dhand, aligning with these precedents, ruled that the proceedings related to the FIR could not be terminated based solely on the compromise. The court allowed the prosecutrix to appear before the Investigating Officer to record her statements, and granted the Investigating Officer the liberty to submit a conclusion report under Section 173 of the CrPC, following the investigation.
This decision reinforces the judiciary's commitment to addressing heinous crimes with the seriousness they warrant, ensuring that such offences are not trivialized through private settlements. The ruling sends a clear message that the societal impact of crimes like rape transcends individual agreements, thereby safeguarding public interest and the integrity of the justice system.
Bottom line:-
Offence of rape under Section 376 IPC cannot be quashed solely on the basis of compromise between the parties, as it is a heinous crime that has a serious impact on society and is not private in nature.
Statutory provision(s): Sections 376 IPC, 482 CrPC, 173 CrPC, 320 CrPC
Shankar Lal Meena v. State of Rajasthan, (Rajasthan)(Jaipur Bench) : Law Finder Doc id # 2925980
