CRL.M.C. 5402/2025 $~59 Q * IN THE HIGH COURT OF DELHI AT NEW DELHI + CRL.M.C. 5402/2025 ANIL KUMAR WASSON & ORS. .....Petitioners Through: Mr. Jujhar Singh, Advocate. versus STATE OF NCT OF DELHI & ORS. .....Respondent Through: Mr. Yudhvir Singh Chauhan, APP W/SI Sharmila Yadav, PS Gulabi Bagh. R2 and R3 in person. CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R % 28.07.2026 1. The petitioners have filed the present petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”) [corresponding to Section 482 of the Code of Criminal Procedure, 1973 (“CrPC”)], seeking quashing of FIR No. 259/2021, dated 08.09.2021, registered at Police Station Gulabi Bagh, under Sections 323/341/354(B)/506/509/34 of the Indian Penal Code, 1860 [“IPC”], alongwith all proceedings arising therefrom, on the ground that the dispute between the parties has been amicably settled. 2. Notice was issued on 08.08.2025, pursuant to which the complainant and another injured victim [respondent Nos. 2 and 3 herein] have entered appearance today. They however do not seek assistance of counsel. 3. The petitioners are present by way of video conference and are This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/08/2026 at 10:53:52 CRL.M.C. 5402/2025 identified by their learned counsel as well as by the Investigating Officer [“IO”]. Respondent Nos. 2 and 3, who are present in Court, are identified by the IO. 4. The petition is taken up for disposal with the consent of the parties. 5. The impugned FIR is registered at the instance of respondent No. 2. As per the allegations in the FIR, respondent No. 2 has stated that the petitioners had parked their scooter very close to the car of respondent No. 2, and when asked to leave some space, an altercation ensued, wherein the respondent No. 2’s dupatta was removed and her husband [respondent No. 3 herein] was injured. 6. The chargesheet has been filed in the present proceedings. 7. During the pendency of the proceedings, the parties, who continue to reside in the same neighbourhood, have amicably settled their dispute by way of a Compromise Deed dated 20.12.2024. 8. The parties confirm that the settlement has been entered into voluntarily and without any coercion or undue pressure. Respondent No. 2 specifically states that allegations under Sections 354B of IPC arose out of a misunderstanding in connection with the neighbourhood dispute. 9. In light of the aforesaid, parties seek quashing of the impugned FIR. 10. The Supreme Court has held that, in appropriate circumstances, High Courts, while exercising their powers under Section 528 of the BNSS (corresponding to Section 482 of the CrPC), may quash criminal proceedings, even in cases involving non-compoundable offences, where a compromise has been reached between the accused and the complainant, particularly when no overriding public interest is adversely This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/08/2026 at 10:53:52 CRL.M.C. 5402/2025 affected. 11. The Supreme Court, in Gian Singh v. State of Punjab & Anr.1 has held as follows: “58. Where the High Court quashes a criminal proceeding having regard to the fact that the dispute between the offender and the victim has been settled although the offences are not compoundable, it does so as in its opinion, continuation of criminal proceedings will be an exercise in futility and justice in the case demands that the dispute between the parties is put to an end and peace is restored; securing the ends of justice being the ultimate guiding factor. No doubt, crimes are acts which have harmful effect on the public and consist in wrongdoing that seriously endangers and threatens the well-being of the society and it is not safe to leave the crime-doer only because he and the victim have settled the dispute amicably or that the victim has been paid compensation, yet certain crimes have been made compoundable in law, with or without the permission of the court. In respect of serious offences like murder, rape, dacoity, etc., or other offences of mental depravity under IPC or offences of moral turpitude under special statutes, like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity, the settlement between the offender and the victim can have no legal sanction at all. However, certain offences which overwhelmingly and predominantly bear civil flavour having arisen out of civil, mercantile, commercial, financial, partnership or such like transactions or the offences arising out of matrimony, particularly relating to dowry, etc. or the family dispute, where the wrong is basically to the victim and the offender and the victim have settled all disputes between them amicably, irrespective of the fact that such offences have not been made compoundable, the High Court may within the framework of its inherent power, quash the criminal proceeding or criminal complaint or FIR if it is satisfied that on the face of such settlement, there is hardly any likelihood of the offender being convicted and by not quashing the criminal proceedings, justice shall be casualty and ends of justice shall be defeated. The above list is illustrative and not exhaustive. Each case will depend on its own facts and no hard-and-fast category can be prescribed.”2 Further, in Narinder Singh & Ors. v. State of Punjab & Anr.3, the 1 2012 10 SCC 303. 2 Emphasis supplied. 3 (2014) 6 SCC 466. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/08/2026 at 10:53:52 CRL.M.C. 5402/2025 Supreme Court has also laid down guidelines for High Courts while accepting settlement deeds between parties and quashing the proceedings. The relevant observations in the said decision read as under: “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 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 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/08/2026 at 10:53:52 CRL.M.C. 5402/2025 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.”4 12. The offences alleged in the subject FIR arise from a personal dispute between the parties and are essentially private in nature. The allegations stem from a neighbourhood misunderstanding due to a trivial parking dispute, and does not engage any wider public interest or grave criminality. In accordance with the principles laid down by the Supreme Court, it is relevant to note that respondent Nos. 2 and 3 has affirmed the voluntary nature of the settlement before the Court. In these circumstances, the continuation of criminal proceedings is unlikely to result in a conviction and would serve no practical purpose, while only adding to the burden on the justice system and consuming public resources unnecessarily. 13. Having regard to the circumstances giving rise to the impugned FIR, I accept the suggestion of Mr. Chauhan that this is an appropriate case for the imposition of costs. The petitioners are collectively directed to deposit Rs. 20,000/-, to be paid to Delhi High Court Bar Association Costs Account [A/C No. 15530110179338; IFSC No. UCBA0001553; UCO Bank, Delhi High Court Branch]. The petitioners shall place a compliance affidavit on record within two weeks thereafter. 14. In view of the foregoing discussion, the petition is allowed, and FIR No. 259/2021, dated 08.09.2021, registered at Police Station Gulabi Bagh, under Sections 323, 341, 354(B), 506, 34 and 509 of IPC, alongwith with all proceedings arising therefrom, is hereby quashed. 4 Emphasis supplied. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/08/2026 at 10:53:52 CRL.M.C. 5402/2025 15. The parties shall remain bound by the terms of the settlement. 16. The petition accordingly stands disposed of. PRATEEK JALAN, J JULY 28, 2026 ‘pv’/AN/ This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/08/2026 at 10:53:52