Prashant Prakash Ratnaparki & Ors. v. State of Maharashtra & Anr.
Criminal Appeal No(s). of 2025 (Arising out of SLP (Crl.) No. 2628 of 2025)
Decision Date: November 17, 2025
Bench: Justices Vikram Nath and Sandeep Mehta

I. Background of the Case

An FIR was registered against the appellants alleging a series of offences that formed part of a single incident. These included:

• Sections 115(2), 351(2), 351(3), 352 of the BNS
  (equivalent to Sections 326, 506, 504 of the IPC)
• Section 310(2) of the BNS
  (equivalent to Section 395 of the IPC – Dacoity)

During the investigation, the complainant (respondent No. 2) submitted a voluntary affidavit stating that the dispute had been compromised and he did not wish to pursue the case.

The Bombay High Court (Aurangabad Bench) accepted the compromise only in respect of some offences and partially quashed the FIR by dropping the lesser charges. However, it decided to retain the charge of dacoity, holding that the offence under Section 395 IPC (now Section 310(2) BNS) was serious and non-compoundable.

This resulted in the appellants approaching the Supreme Court.

II. Legal Issue

Whether the High Court was justified in quashing the FIR for certain offences based on compromise while simultaneously allowing the offence of dacoity to survive, even though all offences arose from the same transaction?

III. Supreme Court’s Ruling

The Supreme Court set aside the Bombay High Court’s order and held that:

1. FIR Cannot Be Split When the Incident Is One Single Transaction

The Court observed that all alleged offences stemmed from one continuous, inseparable incident. The factual foundation was common for every charge.

Thus, the FIR:

• could be quashed wholly, or
• could be sustained wholly,

but not split into parts merely based on the nature of particular offences.

2. Compromise Applied to Lesser Offences Applies to Dacoity Also

The bench held:

“The compromise that was accepted as genuine and sufficient to quash the other offences equally dilutes the foundation of the charge of dacoity.”

In simpler terms:

• If the statements and allegations were unreliable or withdrawn for the lesser offences,
• then those same statements cannot continue to sustain the gravest charge.

3. High Court’s Approach Was Conceptually Erroneous

The Court criticised the High Court for:

• adopting a selective approach
• treating one FIR as containing separable offences
• not appreciating that all allegations emerged from a single narrative

Once the High Court exercised jurisdiction under Section 482 CrPC (Inherent Powers) to quash, the same logic should have applied to all offences that stood on the same factual matrix.

IV. Key Observations by the Supreme Court

The bench of Justices Vikram Nath and Sandeep Mehta held:

1. Inseparability of Acts:
   The factual basis for all the offences was inseparable and part of one continuous incident.
2. Effect of Compromise:
   The voluntary affidavit of the complainant removed the factual foundation for all charges, including the charge of dacoity.
3. Uniform Treatment of the FIR:
   Once quashing was accepted on merits for some offences, there was no justification for retaining the offence under Section 310(2) BNS.
4. High Court’s Error:
   The High Court erroneously split the offences and adopted an approach contrary to settled principles governing Section 482 CrPC jurisdiction.

V. Ratio Decidendi (Legal Principle)

When all offences alleged in an FIR arise from a single, continuous transaction, the High Court cannot partially quash certain charges while retaining others based on the same set of allegations. A compromise or dilution of factual allegations affects the entire FIR as a whole.

VI. Significance of the Judgment

1. Reinforces the “Single Transaction Doctrine”

The judgment affirms that offences arising from the same incident must be treated holistically, not in fragments.

2. Clarifies the Scope of Section 482 CrPC

The decision strengthens jurisprudence on quashing proceedings:

• Courts cannot selectively apply compromise to some offences and ignore others.
• Doing so may result in an illogical and unbalanced approach.

3. Protects Accused from Inconsistent Judicial Outcomes

If the complainant recants, compromises, or withdraws allegations, the accused should not face a disproportionate outcome for one isolated charge derived from the same factual background.

4. Prevents Misuse of Serious Charges like Dacoity

The Court indirectly warns against allowing grave charges to continue where the factual substratum has collapsed due to compromise.

VII. Conclusion

The Supreme Court allowed the appeal and fully quashed the FIR, holding that the High Court’s decision was legally unsustainable. The Court reiterated that prosecution cannot selectively survive when the entire foundation of allegations has been rendered doubtful or withdrawn through a genuine compromise.

This judgment is a significant reaffirmation of the principles governing quashing of criminal proceedings, especially in cases involving multiple offences arising from a single incident.