Punjab & Haryana High Court Compounds Section 420 IPC Conviction on Basis of Compromise; Sets Aside Sentence in Revision

Case Name: Amarjit Thapar v. State of Punjab and Another
Date of Judgment: 08 December 2025
Citation: CRR-2895-2025
Bench: Hon’ble Mr. Justice Aman Chaudhary

Held: The Punjab and Haryana High Court allowed a criminal revision petition and compounded the offence under Section 420 IPC on the basis of a genuine compromise arrived at between the parties after conviction. The Court held that even in non-compoundable offences, the High Court can exercise its revisional and inherent jurisdiction to compound the offence where the dispute is essentially private in nature, the compromise is voluntary, and continuation of proceedings would serve no useful purpose.

Summary: The petitioner challenged his conviction and sentence for the offence of cheating under Section 420 IPC, which arose out of allegations that money was taken from the complainant on the assurance of sending his son abroad, but the promise was not fulfilled. The trial court convicted the petitioner, and the appellate court affirmed the conviction.

During the pendency of the revision petition, the parties entered into an amicable compromise with the intervention of village elders and respectable persons. The complainant expressly stated that he had no objection to compounding the offence and setting aside the conviction. Pursuant to directions of the High Court, the matter was verified by the Judicial Magistrate, who reported that the compromise was genuine, voluntary, and free from coercion, and that the petitioner was a first-time offender with no other criminal involvement.

The High Court examined the scope of its powers in revision and relied upon the principles laid down by the Supreme Court in Ramgopal v. State of M.P. and other precedents, holding that the bar under Section 320 CrPC does not curtail the High Court’s jurisdiction to compound offences in appropriate cases. Considering the private nature of the dispute, clean antecedents of the petitioner, voluntary compromise, and the absence of any adverse societal impact, the Court held that refusal to accept the compromise would defeat the ends of justice.

Decision: The criminal revision petition was allowed. The judgment of conviction and order of sentence passed by the courts below were set aside, the offence was compounded, and the petitioner was acquitted. The bail bonds were ordered to stand discharged.