The Andhra Pradesh High Court has affirmed that voluntary compromise between parties in cases under the SCs/STs (Prevention of Atrocities) Act, 1989, can justify acquittal even for serious offences, overriding the presumption that such crimes are non-compoundable. This ruling reinforces the judiciary’s evolving recognition of restorative justice in appropriate contexts, particularly where the victim consents without coercion.
Background & Facts
The Dispute
The appellant, Pandugayala Venkata Narasimhulu, was convicted by the Special Judge for Trial of Offences under the SCs/STs (PoA) Act, 1989, for offences under Sections 354, 323, and 506 of the Indian Penal Code, and Sections 3(1)(r), 3(1)(s), and 3(2)(va) of the SCs/STs (PoA) Act, 1989. The charges arose from an alleged assault and intimidation against the second respondent, Chevuri Venkata Ramanamma, a woman from a Scheduled Caste community.
Procedural History
- 2017: FIR registered and trial commenced before the Special Judge at Ongole.
- January 11, 2022: Trial court convicted the appellant and sentenced him.
- 2022: Criminal Appeal No. 30/2022 filed under Section 374(2) CrPC challenging the conviction.
- November 25, 2025: Court permitted the de facto complainant to be impleaded as respondent No. 2.
- 2025: Both parties filed applications seeking permission to compromise and to set aside the conviction.
Relief Sought
The appellant and the complainant jointly sought to record their voluntary compromise and to have the conviction set aside, arguing that the dispute had been amicably resolved and that no public interest would be compromised by acquittal.
The Legal Issue
The central question was whether a voluntary compromise between the accused and the victim in a case involving offences under Sections 3(1)(r), 3(1)(s), and 3(2)(va) of the SCs/STs (PoA) Act, 1989 - traditionally viewed as non-compoundable - can justify acquittal, and whether the principles laid down in Gian Singh v. State of Punjab apply to such cases.
Arguments Presented
For the Appellant
Counsel for the appellant relied on Gian Singh v. State of Punjab to argue that courts possess inherent power under Section 482 CrPC to quash proceedings where a genuine compromise is recorded, even in serious offences. He emphasized that the complainant, a woman from a Scheduled Caste, had voluntarily withdrawn her allegations, no coercion was evident, and the compromise was in the interest of social harmony. He contended that the PoA Act’s punitive intent does not preclude judicial discretion to end proceedings where justice is served through reconciliation.
For the Respondent
The de facto complainant, through her counsel, affirmed that the compromise was entirely voluntary, free from pressure, and motivated by personal reconciliation. The State, while not opposing the compromise, acknowledged the seriousness of the charges but conceded that the court’s power to quash under Section 482 CrPC remained intact, particularly where the victim’s consent is unequivocal.
The Court's Analysis
The Court examined the nature of offences under the SCs/STs (PoA) Act and the scope of judicial power to quash proceedings under Section 482 CrPC. It noted that while the Act is designed to protect marginalized communities and deter atrocities, it does not extinguish the court’s inherent jurisdiction to prevent abuse of process or secure ends of justice.
"The object of the PoA Act is to prevent atrocities and ensure justice to the Scheduled Castes and Scheduled Tribes, but it does not bar the High Court from exercising its inherent powers under Section 482 CrPC to quash proceedings where a genuine compromise is recorded without any coercion or malafide."
The Court distinguished between the prosecutorial duty to pursue public interest and the judicial duty to prevent miscarriage of justice. It held that when the victim, who is the primary stakeholder, voluntarily consents to settlement and the court is satisfied of the genuineness of the compromise, the continuation of criminal proceedings serves no useful purpose.
The Court reaffirmed the Gian Singh principle: compromise can be a valid ground for quashing proceedings even in heinous offences, provided the court is convinced of the voluntariness and bona fides of the settlement. It found no evidence of coercion, undue influence, or public interest harm in this case.
The Verdict
The appellant won. The Court held that a voluntary and genuine compromise between the accused and the victim in an SC/ST (PoA) Act case permits acquittal, even for offences under Sections 3(1)(r), 3(1)(s), and 3(2)(va). The conviction was set aside, the appellant acquitted, and any fine paid was ordered to be refunded.
What This Means For Similar Cases
Compromise Can Override Non-Compoundability
- Practitioners may now argue that non-compoundability under the PoA Act does not bar quashing under Section 482 CrPC if the compromise is voluntary and genuine.
- Courts must conduct a two-step inquiry: (1) Was the compromise truly voluntary? (2) Does quashing serve the ends of justice?
- Evidence of reconciliation - such as written affidavits, Aadhaar verification, and oral affirmation in court - is critical.
Judicial Discretion Trumps Rigid Interpretation
- The judgment signals a shift from mechanical application of statutory non-compoundability to context-sensitive justice.
- Prosecutors must now assess whether pursuing a case after compromise aligns with public interest or merely perpetuates adversarial conflict.
- Defence counsel should proactively file compromise applications early, supported by affidavits and identity verification.
Victim’s Autonomy Is Central
- The complainant’s voice is now legally recognized as decisive in determining whether proceedings should continue.
- Courts must avoid treating victims of caste-based crimes as passive instruments of state prosecution.
- This ruling empowers victims to seek closure without fear of being forced into prolonged litigation.
