Allahabad High Court

SANTOSH SINGH AND ANOTHERversusSTATE OF U.P. AND ANOTHER

Decided: 25 March 2026
Bench: ABDUL SHAHID

Holding

The Court held that, given a voluntarily verified compromise and the private nature of the dispute, the criminal proceedings under the SC/ST Act must be quashed.

Summary

The appellants filed a criminal appeal under Section 14-A(1) of the Scheduled Caste and Scheduled Tribes (Prevention of Atrocities) Act, 1989, seeking quash of proceedings arising from a charge‑sheet filed on 14‑08‑2025. Both parties submitted a compromise deed, which was verified by the Special Judge handling the case, and asserted that the settlement was made voluntarily without coercion. The Court examined Supreme Court precedents (Ramawatar v. State of M.P., 2022 SCC 635 and Ghulam Rasool Khan v. State of U.P., 2022 ADJ 691) that allow compounding of offences under the SC/ST Act when the dispute is essentially private and the victim’s free will is established. Finding that the compromise satisfied these criteria and that the underlying offences were not motivated by caste, the Court exercised its power under Section 14‑A(1) to quash the criminal proceedings. Consequently, the appeal was allowed and the case was dismissed.

Issues considered

Whether a compromise can be accepted and the proceedings quashed in a case under the SC/ST (Prevention of Atrocities) Act.
Whether the underlying offences are of a private nature and not motivated by the victim's caste, permitting compounding under Section 14‑A(1).
Whether the victim’s consent was free of coercion or undue influence, as required by jurisprudence.

Legislation cited

Code of Criminal Procedure, 1973 — s. 482
Scheduled Caste and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 127(2), 132, 14-A(1), 221, 224, 3(1) द, 3(1) ध, 3(2)5क, 3(5), 351(3), 352 BNS

Subjects

SC/ST Act
compromise
quash of proceedings
Section 14-A
private dispute
free will
coercion
Section 482 CrPC
Article 142 Constitution

Judgment

HIGH COURT OF JUDICATURE AT ALLAHABAD

CRIMINAL APPEAL No. - 11818 of 2025

Santosh Singh And Another
.....Appellant(s)
Versus
State of U.P. and Another
.....Respondent(s)

Counsel for Appellant(s) : Sarve Nazir, Vipul Kumar Dubey, Zafar
Abbas
Counsel for Respondent(s) : Manoj Kumar Dubey, G.A.

Court No. - 53
HON'BLE ABDUL SHAHID, J.

1. Heard learned counsel for the parties.

2. This criminal appeal under Section 14-A(1) of The Scheduled Caste and
Scheduled Tribes (Prevention of Atrocities) Act, 1989 has been filed against
the Charge-sheet dated 14.08.2025, summoning and cognizance order dated
21.08.2025 in Criminal Case No. 851 of 2025 (State vs. Santosh Singh and
others) arising out of Case Crime No. 242 of 2025 under section 3(5),
127(2), 132, 221, 224, 351 (3), 352 BNS and section 3 (1) द, 3 (1) ध and
Section 3(2)5क SC/ST (Prevention of Atrocities) Act, 1989 Police Station
Raunapar District Azamgarh, pending in the court of Special Judge S.C. /
S.T. (P.A.) Act, Azamgarh.

3. The parties before this Court have made a request that they have entered
into a compromise in this matter and have settled all the disputes between
them and now they do not want to proceed with this matter. It is further
submitted that in compliance of the order of this Court dated 16.01.2026, the
compromise deed submitted by the parties has been verified by the Special
Judge, (SC/ST Act), Azamgarh. Further record discloses that verification
report dated 11.02.2026 has also been received, which is on record.

4. Learned counsel for the appellants has submitted before this Court that the
compromise entered into between the parties has been made without any
coercion or undue influence upon the informant of this case and is a result of
free will and consent of the parties.

5. It appears from perusal of the record that the present case is having a
nature of purely private dispute and prima facie it also appears that the
alleged offence has not been committed on account of the caste of the
informant and except some offence under SC/ST Act, minor offences have
been levelled against the accused. Further, the compromise between the
parties is the result of free will and consent of the informant-opposite party
no. 2 without any undue influence.
CRLA No. 11818 of 2025
2

6. The question as to whether a compromise can be verified and accepted in
a case relating to an offence under SC/ST Act has been answered by the
Supreme Court in the case of Ramawatar Vs. State of M.P. (2022) 13 SCC
635. Paragraph no. 17 of the said judgment is quoted herein below:-

"17. On the other hand, where it appears to the Court that the
offence in question, although covered under the SC/ST Act, is
primarily private or civil in nature, or where the alleged offence
has not been committed on account of the caste of the victim, or
where the continuation of the legal proceedings would be an
abuse of the process of law, the Court can exercise its powers to
quash the proceedings. On similar lines, when considering a
prayer for quashing on the basis of a compromise/settlement, if
the Court is satisfied that the underlying objective of the Act
would not be contravened or diminished even if the felony in
question goes unpunished, the mere fact that the offence is
covered under a "special statute" would not refrain this Court or
the High Court, from exercising their respective powers under
Article 142 of the Constitution or Section 482 Cr.P.C."

7. It has been further held in paragraph no. 19 of the said judgment, which is
quoted herein under:-

"19. We may hasten to add that in cases such as the present, the
Courts ought to be even more vigilant to ensure that the
complainant-victim has entered into the compromise on the
volition of his/her free will and not on account of any duress. It
cannot be understated that since members of the Scheduled Caste
and Scheduled Tribe belong to the weaker sections of our
country, they are more prone to acts of coercion, and therefore
ought to be accorded a higher level of protection. If the Courts
find even a hint of compulsion or force, no relief can be given to
the accused party. What factors the Courts should consider,
would depend on the facts and circumstances of each case".

8. A perusal of the Full Bench judgment in the case of Ghulam Rasool
Khan And Others vs State Of U.P And Another, 2022 (8) ADJ 691
reveals that a matter under the SC/ST Act may be compounded in a criminal
appeal under section 14-A(1) of SC/ST Act and there is no need to take
recourse of U/s. 482 Cr.P.C. for the same.

9. In view of the aforesaid, this Court finds that since the parties have
entered into compromise which has already been verified by the trial court,
the entire proceedings of criminal case emanating from the Charge-sheet
dated 14.08.2025, summoning and cognizance order dated 21.08.2025 in
Criminal Case No. 851 of 2025 (State vs. Santosh Singh and others) arising
out of Case Crime No. 242 of 2025 under section 3(5), 127(2), 132, 221,
224, 351 (3), 352 BNS and section 3 (1) द, 3 (1) ध and Section 3(2)5क
SC/ST (Prevention of Atrocities) Act, 1989 Police Station Raunapar District
Azamgarh, pending in the court of Special Judge S.C. / S.T. (P.A.) Act,
CRLA No. 11818 of 2025
3

Azamgarh, are hereby quashed and the present criminal appeal is allowed in
terms of compromise entered into between both the parties.
March 26, 2026
K.K. Maurya
(Abdul Shahid,J.)

Digitally signed by :-
KAMLESH KUMAR MAURYA
High Court of Judicature at Allahabad

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