The Allahabad High Court has ruled that criminal proceedings under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) may be quashed on the basis of a compromise between the parties directly by way of a criminal appeal under Section 14‑A(1) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Court held that there is no necessity to invoke the High Court’s inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 (CrPC) where the statutory remedy under the SC/ST Act is available. This decision was rendered by a bench presided over by Justice Shekhar Kumar Yadav.
The matter before the Court involved a Criminal Appeal filed under Section 14-A(1) of the SC/ST Act by the appellants, who sought quashing of the entire proceedings — including the charge sheet and the criminal summons issued by the Special Court (SC/ST Act). The offences alleged against them included sections of the Indian Penal Code (such as 147, 323, 500, 504, 506) read with provisions of the SC/ST Act (Section 3(2)(va)). The appellants submitted that the dispute was of a purely private nature and that they had arrived at a full compromise with the complainant, without any coercion or undue influence. They contended that continuing the prosecution under the SC/ST Act, given the compromise, would amount to abuse of the process of law.
It was further informed before the Court that the trial court had already verified the compromise — as directed by a prior order — and accepted that the parties had genuinely settled their disputes. Relying on this, the appellants argued that the criminal proceedings should be terminated without the need to separately resort to the inherent powers of the High Court under Section 482 CrPC.
In its judgment, the High Court referred to the full-bench decision in Ghulam Rasool Khan and Others v. State of U.P. and Another, where the Court had previously addressed whether the High Court’s 482-CrPC power could be invoked when statutory remedy under Section 14-A existed. The full bench in that case had held that when a statutory appeal under Section 14-A is available, the aggrieved party cannot be permitted to invoke inherent jurisdiction under Section 482 CrPC to quash the proceedings. The present decision aligns with that precedent, reaffirming that the appeal under Section 14-A is the proper and exclusive remedy for compounding and quashing SC/ST Act proceedings on compromise.
Accordingly, Justice Yadav applying this legal principle held that the present appeal under Section 14-A was maintainable, and that the criminal proceedings ought to be quashed in view of the compromise reached between the parties. The summoning order and the charge sheet were set aside, thereby terminating the SC/ST Act proceedings against the appellants.
Further, the Court directed that the compensation amount — which had been given to the complainant (Opposite Party No. 2) as part of the compromise — must be returned to the appropriate authority. The complainant was ordered to refund the compensation within one week of the judgment, as a condition for quashing the case.
The Court’s ruling underscores that where the statutory mechanism under the SC/ST Act has been availed, parties to a private dispute that was initially prosecuted under the Act may end their litigation through compromise, and the court — through Section 14-A appeal — has the power to quash the proceedings without needing to invoke inherited powers under Section 482 CrPC. This decision clarifies the procedural route for compounding SC/ST Act cases and streamlines the remedy for parties seeking closure following compromise.
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