SC/ST Act Allegations Cannot Be Quashed Merely on Compromise: P&H High Court Refuses to Quash Job-Fraud FIR
Case Name: Param Pal Singh @ Param Walia & Ors. v. State of Punjab & Anr.
Date of Judgment: 05 March 2026
Citation: CRM-M-54787-2025
Bench: Justice Sumeet Goel
Held: The Punjab and Haryana High Court held that criminal proceedings involving allegations under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act cannot ordinarily be quashed merely on the basis of compromise between the parties. Offences involving caste-based humiliation and intimidation have a broader societal impact and cannot be treated as purely private disputes capable of settlement.
Summary: The petitioners approached the High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking quashing of FIR No. 54 dated 12.07.2025 registered at Police Station Maloud, District Khanna, Ludhiana under Sections 420, 506, 120-B IPC and Section 3(1)(R) of the SC/ST (Prevention of Atrocities) Act on the basis of a compromise dated 20.07.2025 allegedly effected with the complainant.
The complainant alleged that the petitioners induced him on the false pretext of securing a government job and dishonestly obtained ₹2,05,000 from him. When the complainant later demanded the return of the money, the petitioners allegedly neither refunded the amount nor returned his documents. Instead, he was allegedly subjected to caste-based derogatory remarks in public view and threatened with a pistol.
The petitioners contended that the dispute was essentially financial in nature and had been amicably resolved with the intervention of respectable persons. They submitted that the entire amount had been repaid and the complainant had filed an affidavit acknowledging the compromise and expressing his unwillingness to pursue the criminal proceedings.
The State opposed the petition, arguing that the allegations were serious as they involved cheating under the guise of providing government employment along with caste-based humiliation and criminal intimidation. It was submitted that offences under the SC/ST Act are non-compoundable and cannot be quashed merely on the basis of a private compromise.
The Court observed that although the High Court possesses wide inherent powers under Section 528 BNSS to quash criminal proceedings to secure the ends of justice, such power must be exercised with caution. Where allegations disclose serious offences involving moral turpitude, intimidation with a weapon, and insult on the basis of caste, the Court must be slow in exercising its inherent jurisdiction.
The Court further noted that offences under Section 3(1)(R) of the SC/ST Act are not merely private disputes between individuals but affect the dignity of members of Scheduled Castes and Scheduled Tribes and carry significant social implications. In such cases, the possibility of pressure or coercion leading to compromise cannot be ignored, particularly when parties belong to the same locality.
Given the gravity of the allegations, including cheating on the promise of a government job, caste-based humiliation, and criminal intimidation with a firearm, the Court held that the compromise placed on record did not justify quashing the FIR at the investigation stage.
Decision: The Punjab and Haryana High Court dismissed the petition seeking quashing of FIR No. 54 dated 12.07.2025, holding that the allegations involving cheating and offences under the SC/ST Act could not be quashed merely on the basis of a compromise between the parties.