Compromise in Village Dispute Leads to Quashing of Conviction; Punjab & Haryana HC Sets Aside Robbery Charge for Lack of Proof

Case Name: Deepak @ Radhey and Others v. State of Haryana and Others

Date of Judgment: 07 March 2026

Citation: CRA-S-1949-2025

Bench: Justice Vinod S. Bhardwaj

Held: The Punjab & Haryana High Court set aside the conviction of the appellants under Section 379-B IPC after finding that the prosecution failed to prove the alleged snatching beyond reasonable doubt. The Court further allowed compounding of the remaining offences in view of a genuine compromise between the parties and quashed the conviction and sentence, subject to payment of costs.

Summary: The appeals were filed against the judgment of conviction dated 01.05.2025 and order of sentence dated 07.05.2025 passed by the Sessions Judge, Narnaul, whereby the appellants had been convicted under Sections 148, 323, 341, 506 and 379-B read with Section 149 IPC.

The prosecution case arose from an incident dated 04.11.2021 in which the complainant Sahil alleged that while he was travelling towards village Meghanwas, he was intercepted by several accused persons who assaulted him using weapons including an iron rod, danda and barchhi. He further alleged that the accused threatened to kill him and later attacked his father and uncle when they were on their way to the hospital. During this incident, the accused allegedly snatched Rs.38,000 and a mobile phone and damaged their motorcycle.

The trial court convicted the accused and imposed sentences including rigorous imprisonment up to ten years for the offence under Section 379-B IPC, along with other sentences for allied offences.

During the pendency of the appeals before the High Court, the appellants and the complainant entered into an amicable compromise. The High Court directed the parties to appear before the Illaqa Magistrate to verify the genuineness of the compromise. The Judicial Magistrate First Class, Mohindergarh submitted a report confirming that the compromise was voluntary and without coercion.

The State opposed the plea for compounding on the ground that the offences involved violence and were non-compoundable. However, the complainant and injured persons supported the compromise and expressed that they did not wish to pursue the matter further.

On examining the evidence, the High Court found that the charge under Section 379-B IPC was not proved beyond reasonable doubt. Although the prosecution alleged that a mobile phone had been snatched and later recovered from one of the accused, the Court noted significant deficiencies in the evidence. There was no description of the make, model, brand, or IMEI number of the mobile phone, nor were any documents such as purchase bills, CAF records, or SIM details produced to establish ownership. The alleged recovery was linked to the complainant only through identification by the victim, which the Court held to be insufficient in the absence of distinguishing features. Consequently, the Court granted the benefit of doubt to the accused and set aside the conviction under Section 379-B IPC.

With respect to the remaining offences under Sections 148, 323, 341 and 506 IPC, the Court noted that the dispute had arisen from a village-level altercation between persons known to each other and was essentially personal in nature. The incident had occurred in 2021 and a substantial period had passed since then. The injured persons had recovered and had voluntarily entered into a compromise with the accused.

The Court also observed that the parties belonged to the same village and continuation of criminal proceedings could perpetuate discord, whereas acceptance of the compromise would promote reconciliation and social harmony.

Relying on the Full Bench judgment in Kulwinder Singh v. State of Punjab, the Court reiterated that the High Court possesses inherent powers under Section 482 CrPC to permit compounding or quashing of criminal proceedings even in non-compoundable offences where such exercise is necessary to secure the ends of justice.

Considering the genuine compromise, the absence of criminal antecedents, and the restoration of harmony between the parties, the Court held that continuation of proceedings would serve no meaningful purpose and would amount to abuse of the process of law.

Decision: The High Court allowed the appeals and set aside the judgment of conviction dated 01.05.2025 and the order of sentence dated 07.05.2025 passed by the Sessions Judge, Narnaul. The criminal proceedings were quashed in view of the compromise between the parties.