IN THE HIGH COURT OF PUNJAB & HARYANA 289 Ranjit Singh Cheema State of Punjab and a CORAM : HON'BLE MR. Present :- Mr. Lakshay Bector for the petitioner Mr. Saurav Verma, Addl. AG, Punjab. Mr. Saurav Kanojia for respondent No. VINOD S. BHARDWAJ Prayer in the present petition is for quashing of FIR bearing No.22 dated 20.03.2024 registered under Sections 435, 436, 427, 34 (Section 201 added later on) of the Indian Penal Code, 1860, at Police Station Sudhar, Ludhiana, along with all subsequent proc basis of compromise dated 27.10.2025 (Annexure P 2. Briefly summari statement of Maninder Singh Litt, son of Rajinder Singh Litt, resident of Village New Abadi Akalgarh, Teh of which is extracted as under: “Statement of Maninder Singh Litt, son resident of New Abadi, Akalgrah, Police Station Sudhar, District Ludhiana, aged 31 years, mobile number 98150 stated that "I am a resident of the above I am engaged in the business of sale and purchase of he related IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH CRM-M-61076 Date of decision: Cheema and another VERSUS and another HON'BLE MR. JUSTICE VINOD Mr. Lakshay Bector, Advocate, for the petitioners. Mr. Saurav Verma, Addl. AG, Punjab. r. Saurav Kanojia, Advocate, for respondent No.2. S. BHARDWAJ, J. (Oral) Prayer in the present petition is for quashing of FIR bearing No.22 dated 20.03.2024 registered under Sections 435, 436, 427, 34 (Section 201 added later on) of the Indian Penal Code, 1860, at Police Station Sudhar, Ludhiana, along with all subsequent proceedings arising therefrom on the basis of compromise dated 27.10.2025 (Annexure P Briefly summarized, the aforesaid FIR was registered on the Maninder Singh Litt, son of Rajinder Singh Litt, resident of Village New Abadi Akalgarh, Tehsil Raikot, District Ludhiana, which is extracted as under:- Statement of Maninder Singh Litt, son resident of New Abadi, Akalgrah, Police Station Sudhar, District Ludhiana, aged 31 years, mobile number 98150 stated that "I am a resident of the above I am engaged in the business of sale and purchase of he related supplements. I own a vehicle IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH 61076-2025(O&M) Date of decision: 22.01.2026 ...Petitioner(s) ...Respondent(s) JUSTICE VINOD S. BHARDWAJ Mr. Saurav Verma, Addl. AG, Punjab. Prayer in the present petition is for quashing of FIR bearing No.22 dated 20.03.2024 registered under Sections 435, 436, 427, 34 (Section 201 added later on) of the Indian Penal Code, 1860, at Police Station Sudhar, eedings arising therefrom on the basis of compromise dated 27.10.2025 (Annexure P-2). aforesaid FIR was registered on the Maninder Singh Litt, son of Rajinder Singh Litt, resident of sil Raikot, District Ludhiana, relevant part Statement of Maninder Singh Litt, son of Rajinder Singh Litt, resident of New Abadi, Akalgrah, Police Station Sudhar, District Ludhiana, aged 31 years, mobile number 98150-67016 stated that "I am a resident of the above-mentioned address and I am engaged in the business of sale and purchase of health- I own a vehicle - a Jeep Compass, bearing SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -2- registration number PB-10-HC-7350, model 2019, which stands registered in my name. Yesterday, on 19.03.2024, at about 07:00 PM, I had returned from Mullanpur in my above said vehicle after bringing some goods (health supplements). Upon reaching back, I parked the above said vehicle along with the goods (health supplements) at a short distance from my house, near the residence of Jarnail Singh Deol son of Hari Singh Deol, resident New Abadi, Akalgrah. At about 11:00 PM, someone knocked at the door of my house. When I went outside and opened the door, I saw Balwinder Singh son of Karmikar Singh, resident of Akalgrah, standing there. He informed me that the car parked outside had caught fire. When I went out to see, I noticed that the vehicle was engulfed in flames. I immediately started pouring water and sand on the vehicle to extinguish the fire and raised a loud alarm. Upon hearing the commotion, members of my family and local residents gathered and helped me in putting out the fire. After some time, the fire was brought under control. However, by then, the seats, entire interior, roof, doors, rear-right tyre, and window glasses of the vehicle had been completely burnt. Thereafter, I checked the CCTV footage from the camera installed at the house of Jarnail Singh son of Hari Singh, resident of New Abadi, Akalgrah, on my own. Upon viewing it, I foundthat two unidentified persons had arrived on a motorcycle, out of whom one clean-shaven man poured petrol or similar inflammable liquid on the rear-right tyre of my car and set it on fire. After igniting the fire, both of them fled from the spot on their motorcycle. I am producing the video footage of the incident before you. Therefore, necessary legal action may kindly be taken against SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -3- the unknown accused persons. Today, I have appeared along with my father Rajinder Singh, and have given my statement, which has been read over to me and found correct. Sd/- Maninder Singh Confirmed by: Sd/- Rajinder Singh Attested by: Sd/- Rajdeep Singh, ASI, 20.03.2024.” 3. However, with the intervention of the respectables, the parties have decided to compromise the matter. Hence, the present petition. The parties were thus directed to appear before the learned trial Court/Illaqa Magistrate vide order dated 03.11.2025 of this Court, to get their statements recorded regarding the compromise arrived at between the parties and a report in this regard was called for. 4. Pursuant to the said order, a report has been received from the Judicial Magistrate First Class, Jagraon, vide Memo No.348 dated 29.11.2025. The relevant extract of the report is reproduced as under:- “The report as desired by the Hon'ble Court is respectfully submitted as under:- (I) As per the information provided by HC Sukhdev Singh no. 211/LDH/R now posted at PS Sudhar, in the dispute/FIR two accused namely Ranjit Singh Cheema S/o Bhagwan Singh and Harinder Singh Cheema @ Harry, Both R/o Village New Abadi Akalgarh, Teh. Raikot, Ludhiana, Punjab are found involved. (II) There is one complainant / victim(s) in the present case. (III) Perusal of photocopy of compromise dated 27.10.2025 placed on record reveals that all the above said accused i.e. Ranjit Singh Cheema S/o Bhagwan Singh and Harinder Singh Cheema @ Harry and one complainant / victims i.e. Maninder Singh Litt S/o Rajinder Singh Litt are party to compromise and signed the same. SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -4- (IV) No other affected person (accused or complainant) is left out to be arrayed as party in the quashing petition before the Hon'ble High Court. (V) As per information provided by HC Sukhdev Singh no. 211/LDH/R now posted at PS Sudhar, there are two accused in the present FIR. No accused has been declared as Proclaimed Offender in any criminal case. (VI) From the statement of parties, it appears that the compromise effected between the parties is genuine, voluntary and without any coercion or undue influence. (VII) Accused Ranjit Singh Cheema S/o Bhagwan Singh was involved in one another case bearing FIR bearing no. 221 dated 30.10.2007 u/s 406, 498-A, 323 IPC PS. Sadar, Ludhiana. However, he has been acquitted in said case.” 5. Learned State Counsel does not dispute the factum of the compromise amongst the parties and does not have any serious objection to the resolution of the dispute amongst the parties. 6. Learned counsel for respondent No.2 reiterates the settlement and his concurrence to the FIR and all the other consequential proceedings being quashed. 7. Hon'ble Supreme Court in the matter of ‘Narinder Singh and others v. State of Punjab and another’, reported as (2014) 6 SCC 466, laid down the following principles for invocation of powers under Section 482 CrPC: SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -5- “29. In view of the aforesaid discussion, we sum up and lay down the following principles by which the High Court would be guided in giving adequate treatment to the settlement between the parties and exercising its power under Section 482 of the Code while accepting the settlement and quashing the proceedings or refusing to accept the settlement with direction to continue with the criminal proceedings: 29.1. Power conferred under Section 482 of the Code is to be distinguished from the power which lies in the Court to compound the offences under Section 320 of the Code. No doubt, under Section 482 of the Code, the High Court has inherent power to quash the criminal proceedings even in those cases which are not compoundable, where the parties have settled the matter between themselves. However, this power is to be exercised sparingly and with caution. 29.2. When the parties have reached the settlement and on that basis petition for quashing the criminal proceedings is filed, the guiding factor in such cases would be to secure: (i) ends of justice, or (ii) to prevent abuse of the process of any court. While exercising the power the High Court is to form an opinion on either of the aforesaid two objectives. 29.3. Such a power is not to be exercised in those prosecutions which involve heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. Such offences are not private in nature and have a serious impact on society. Similarly, for the offences alleged to have been committed under special statute like the Prevention of Corruption Act or the offences committed by public servants while working in that SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -6- capacity are not to be quashed merely on the basis of compromise between the victim and the offender. 29.4. On the other hand, those criminal cases having overwhelmingly and predominantly civil character, particularly those arising out of commercial transactions or arising out of matrimonial relationship or family disputes should be quashed when the parties have resolved their entire disputes among themselves. 29.5. While exercising its powers, the High Court is to examine as to whether the possibility of conviction is remote and bleak and continuation of criminal cases would put the accused to great oppression and prejudice and extreme injustice would be caused to him by not quashing the criminal cases. 29.6. Offences under Section 307 IPC would fall in the category of heinous and serious offences and therefore are to be generally treated as crime against the society and not against the individual alone. However, the High Court would not rest its decision merely because there is a mention of Section 307 IPC in the FIR or the charge is framed under this provision. It would be open to the High Court to examine as to whether incorporation of Section 307 IPC is there for the sake of it or the prosecution has collected sufficient evidence, which if proved, would lead to proving the charge under Section 307 IPC. For this purpose, it would be open to the High Court to go by the nature of injury sustained, whether such injury is inflicted on the vital/delicate parts of the body, nature of weapons used, etc. Medical report in respect of injuries suffered by the victim can generally be the guiding factor. On the basis of this prima facie analysis, the High Court can examine as to whether there is a strong possibility of conviction or the chances of conviction are remote and bleak. In the former case it can refuse to accept the settlement and quash the SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -7- criminal proceedings whereas in the latter case it would be permissible for the High Court to accept the plea compounding the offence based on complete settlement between the parties. At this stage, the Court can also be swayed by the fact that the settlement between the parties is going to result in harmony between them which may improve their future relationship. 29.7. While deciding whether to exercise its power under Section 482 of the Code or not, timings of settlement play a crucial role. Those cases where the settlement is arrived at immediately after the alleged commission of offence and the matter is still under investigation, the High Court may be liberal in accepting the settlement to quash the criminal proceedings/investigation. It is because of the reason that at this stage the investigation is still on and even the charge-sheet has not been filed. Likewise, those cases where the charge is framed but the evidence is yet to start or the evidence is still at infancy stage, the High Court can show benevolence in exercising its powers favourably, but after prima facie assessment of the circumstances/material mentioned above. On the other hand, where the prosecution evidence is almost complete or after the conclusion of the evidence the matter is at the stage of argument, normally the High Court should refrain from exercising its power under Section 482 of the Code, as in such cases the trial court would be in a position to decide the case finally on merits and to come to a conclusion as to whether the offence under Section 307 IPC is committed or not. Similarly, in those cases where the conviction is already recorded by the trial court and the matter is at the appellate stage before the High Court, mere compromise between the parties would not be a ground to accept the same resulting in acquittal of the offender who has already been convicted by the trial court. Here charge is proved under Section 307 IPC and conviction is already recorded of a heinous crime and, SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -8- therefore, there is no question of sparing a convict found guilty of such a crime.” 8. On consideration of the above, the following relevant factors emerge for supplementing a case for invocation of the powers under Section 528 of BNSS, 2023:- (i) The petitioners are alleged to have set the complainant’s car on fire on 19.03.2024. (ii) The petitioners are brothers aged 52 years and 29 years respectively. Continuation of criminal proceedings would hamper their career prospects and affect the discharge of their social obligations. (iii) The petitioners and the respondent-complainant belong to the same village and putting a quietus to the proceedings would bring much-needed peace and tranquillity. (iv) The offence in question cannot be said to be heinous or as an offence that would be shocking to the conscience of the society or public at large. It can also not be termed as one shocking to the conscience of the Court; 9. In view of the report of the Judicial Magistrate First Class, Jagraon and having regard to the settled principles laid down by the Hon’ble Supreme Court on the subject, the instant petition is allowed. The FIR bearing No.22 dated 20.03.2024 registered under Sections 435, 436, 427, 34 (Section 201 added later on) of the Indian Penal Code, 1860, at Police Station Sudhar, Ludhiana, along with all subsequent proceedings arising therefrom, are hereby quashed in view of the compromise dated 27.10.2025 SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document 289 CRM-M-61076-2025(O&M) -9- (Annexure P-2). 10. Petition is allowed in the above terms. 11. Since the main petition stands allowed, learned counsel for the petitioners seeks withdrawal of CRM-1980-2026, hence, the same is accordingly dismissed as withdrawn. 22.01.2026 (VINOD S. BHARDWAJ) Sumit Gusain JUDGE Whether speaking/reasoned : Yes/No Whether reportable : Yes/No SUMIT SINGH GUSAIN 2026.02.03 15:03 I attest to the accuracy and integrity of this document