Bombay High Court Quashes SC/ST Act FIR Following Mutual Compromise Between Parties
The Bombay High Court's Aurangabad bench has delivered a significant ruling by quashing and setting aside a First Information Report (FIR) registered under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act. This decision came during the appeals stage filed by a mother-son duo challenging the rejection of their anticipatory bail pleas by a special judge handling atrocity cases in Rahata, Ahilyanagar district, on July 7, 2025.
Compromise Leads to Case Closure with Conditions
The bench, presided over by Justice Y G Khobragade, took cognizance of the fact that the complainant and the appellants had mutually agreed to enter into a compromise and expressed no desire to pursue the legal case any further. In his order dated February 5, Justice Khobragade emphasized that while the FIR was being quashed due to the settlement, the court imposed a cost of Rs 10,000 each on the two appellants.
This penalty was levied for invoking both police and court machinery unnecessarily and only opting for a compromise after the crime had been formally registered. The bench carefully considered the nature of the FIR in both appeals before reaching this conclusion.
Withdrawal of Costs and Quashing of Counter-FIR
In a notable provision, the court specified that the complainant-woman in the SC/ST Act case would be entitled to withdraw the imposed costs once the appellants deposit the amount. Furthermore, the bench also quashed and set aside a counter-FIR that had been filed based on a complaint by the mother-son duo against the original complainant.
Both these FIRs were originally registered by the Shirdi police station in Ahilyanagar district, stemming from a bitter dispute between two families. The initial complaint accused the mother-son duo of serious offenses including criminal intimidation, intentional insult, and hurling casteist abuses in public view.
Background of the Family Dispute and Legal Proceedings
The counter-FIR filed by the mother-son duo alleged that the woman had committed house trespass for assault, outraging modesty, voluntarily causing hurt, criminal intimidation, intentional insult, and acting with common intention. Advocate Rashmi Kulkarni represented the appellants throughout these legal proceedings.
The High Court had previously granted interim anticipatory bail to the two appellants on November 6, 2025. Earlier, on July 7, 2025, the complainant-woman had submitted a pursis (formal information to the court) with the trial court stating that since her marriage and relocation to her matrimonial home, she had decided to abandon the dispute and had no objection to granting bail to the mother-son duo.
Court's Progressive Approach and Legal Precedents
During the hearing before the High Court on January 8 this year, the bench directed the continuation of interim relief to the appellants. The appellants' advocate subsequently presented a notarized affidavit executed by the complainant-woman confirming that the parties had entered into a compromise and that she had decided to withdraw all complaints lodged against the appellants.
The High Court then summoned both parties to appear in person at the next hearing date to verify the affidavit as a voluntary act. The bench relied on a Supreme Court judgment which established that even in cases under the SC/ST Act, where disputes appear primarily private or civil in nature, and continuation of proceedings would amount to an abuse of process, the High Court possesses the authority to quash such cases.
The bench also referenced a 2024 decision by the Allahabad High Court, which noted that offenses under the SC/ST Act may be compounded in a criminal appeal under Section 14-A(1) of the Act itself, making recourse to Section 482 of the Criminal Procedure Code (which deals with inherent powers of the High Court) unnecessary in such circumstances.
Since no chargesheet had been filed in the case, the question of discharging the appellants did not arise, leading the bench to proceed with quashing the FIR entirely. This ruling underscores the judiciary's balanced approach in handling cases where parties reach amicable settlements, while simultaneously discouraging frivolous litigation through appropriate costs.
