Allahabad High Court

RAM BER KUMAR AND 4 OTHERSversusSTATE OF U.P. AND ANOTHER

Decided: 25 March 2026
Bench: ABDUL SHAHID

Holding

The court held that when an offence under the SC/ST Act is essentially private and the compromise is voluntary, the proceedings may be quashed under Section 14-A(1).

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 that included offences under the IPC and the SC/ST Act. Both parties submitted a compromise deed, which was verified by the Special Judge handling the case. The court examined whether a compromise is permissible in a case covered by the SC/ST Act, relying on the Supreme Court’s decision in Ramawatar v. State of M.P. and a Full Bench judgment of the Allahabad High Court. It found that the alleged offence was essentially a private dispute, not motivated by caste, and that the compromise was entered into voluntarily without coercion. Consequently, the court exercised its power under Section 14-A(1) to quash the charge sheet and allowed the appeal.

Issues considered

Whether a compromise can be accepted and proceedings quashed in a case under the SC/ST Act.
Whether the offence alleged is of a private/civil nature and not motivated by caste.
Whether the verification of the compromise by the trial court satisfies the requirements of Section 14-A(1).
Whether any coercion or undue influence was present in the compromise.

Legislation cited

Code of Criminal Procedure, 1973 — s. 482
Indian Penal Code — s. 147, 323, 504, 506
Scheduled Caste and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 14-A(1), 3(1)da, 3(1)dhA, 3(2)5A

Subjects

SC/ST Act
compromise
quash of proceedings
Section 14-A
private dispute
coercion
verification
special judge

Judgment

HIGH COURT OF JUDICATURE AT ALLAHABAD
CRIMINAL APPEAL No. - 11877 of 2024

Ram Ber Kumar And 4 Others
.....Appellant(s)
Versus

State of U.P. and Another
.....Respondent(s)

Counsel for Appellant(s) : Rakesh Yadav
Counsel for Respondent(s) : G.A., Pradeep Kumar Singh, Vineet
Kumar Yadav

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 09.01.2024, Cognizance Order dated 27.08.2024 in
Criminal Case No.1420 OF 2024 (State Vs. Shivanand yadav others and )
arising out of Case Crime No.760 of 2023 Section under 147, 323, 504, 506
I.P.C. and Section 3 (1) da, dhA and 3 (2) 5A of SC/ST Act, Police Station-
Sahjanwa, District-Gorakhpur, pending in the Court of Special Judge,
SC/ST, Gorakhpur.

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 11.12.2025 the
compromise deed submitted by the parties has been verified by the Special
Judge, (SC/ST Act), Gorakhpur. Further record discloses that verification
report dated 22.12.2025 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
CRLA No. 11877 of 2024
2

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.

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
CRLA No. 11877 of 2024
3

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 Charge Sheet dated 09.01.2024, Cognizance Order
dated 27.08.2024 in Criminal Case No.1420 OF 2024 (State Vs. Shivanand
yadav others and ) arising out of Case Crime No.760 of 2023 Section under
147, 323, 504, 506 I.P.C. and Section 3 (1) da, dhA and 3 (2) 5A of SC/ST
Act, Police Station-Sahjanwa, District-Gorakhpur, pending in the Court of
Special Judge, SC/ST, Gorakhpur, are hereby quashed and the present
criminal appeal is allowed in terms of compromise entered into between
both the parties.

(Abdul Shahid,J.)
March 26, 2026
K.K. Maurya

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

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