CRL.M.C. 4564/2026 & connected matter. $~15 & 16 (Q) * IN THE HIGH COURT OF DELHI AT NEW DELHI + CRL.M.C. 4564/2026 & CRL.M.A. 18960/2026 MOHD FURKAN & ORS. .....Petitioners versus THE STATE OF NCT OF DELHI & ANR. .....Respondents + CRL.M.C. 4626/2026 ABDUL MANNAN & ORS. .....Petitioners versus THE STATE OF NCT OF DELHI & ANR. .....Respondents Appearances: Mr. Hitesh Vali, APP. Mr. Arun Kumar, Mr. Amit Kumar Srivastava, Advocates for petitioners. Respondent No. 2 in person. CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R % 14.07.2026 1. The petitioners have filed these two petitions 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. 442/2015, dated 25.08.2015, registered at Police Station Jafrabad, New Delhi, under Sections 324/506/34 of the Indian Penal Code, 1860 [“IPC”] [subject matter of CRL.M.C. 4564/2026], as well as FIR No. 134/2012, dated 21.05.2012, registered at Police Station Zafrabad, Delhi, under Sections 498A/406/34 of the Indian Penal Code, 1860 [“IPC”], and Section 4 of the Dowry Prohibition Act, 1961 [“DP Act”] [subject matter of CRL.M.C. 4626/2026], alongwith all proceedings arising therefrom, on the ground that the parties have 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 17/07/2026 at 11:12:18 CRL.M.C. 4564/2026 & connected matter. Page 2 of 7 amicably settled their disputes. 2. Issue notice. Mr. Hitesh Vali, learned Additional Public Prosecutor, accepts notice on behalf of the State. Respondent No. 2 is present in person and does not wish to avail the assistance of counsel. 3. The petitioners are present in Court and have been identified by their learned counsel, and the Investigating Officer [“IO”]. Respondent No. 2 is also present in person in Court, and has been identified by the IO. 4. The petitioner No. 1 in CRL.M.C. 4626/2026 [hereinafter, "husband"] and respondent No. 2, who is common to both the petitions [hereinafter, "wife"], were married on 15.12.2009. No child was born out of the wedlock. Owing to matrimonial discord and irreconcilable differences, the parties have been living separately. 5. FIR No. 134/2012 [subject matter of CRL.M.C. 4626/2026] was registered at the instance of the wife against eight persons, including her husband and his family members, who are arrayed as petitioner Nos. 2 to 8 in CRL.M.C. 4626/2026, under Sections 498A/406/34 of the IPC, and Section 4 of DP Act. 6. The marriage between the husband and wife was dissolved in accordance with personal laws on 18.02.2012. 7. Thereafter, on 25.08.2015, respondent No. 2 lodged another complaint against her husband and her brothers-in-laws, who are arrayed as petitioners in CRL.M.C. 4564/2026, resulting in the registration of FIR No. 442/2015 under Sections 324/506/34 of IPC. 8. Chargesheets have been filed in both matters. In CRL.M.C. 4626/2026, mother-in-law of the wife was also named as an accused in the FIR. However, during the pendency of the proceedings, she passed 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 17/07/2026 at 11:12:18 CRL.M.C. 4564/2026 & connected matter. Page 3 of 7 away, and the proceedings against her thus stand abated. 9. During the pendency of the proceedings, the parties have amicably resolved all disputes arising out of their matrimonial and related matters. Settlement pertaining to FIR No. 134/2012 is recorded in a settlement order dated 20.07.2024, under the aegis of the Delhi Mediation Centre, Karkardooma Courts, which contemplates payment of Rs. 5,25,000/- by the husband to the wife. Subsequently, the parties executed a further Settlement Agreement dated 12.06.2026. Under the said agreement, the parties agreed that FIR No. 442/2015 would also stand settled upon payment of the same amount of Rs. 5,25,000/- to the wife. 10. The wife, who is present before the Court, has affirmed that she has amicably resolved their disputes and no longer wishes to pursue the criminal proceedings against her husband and his relatives. She submits that the allegations framed under Section 324 of the IPC in CRL.M.C. 4564/2026 arose from a misunderstanding and were incidental to matrimonial disputes. Although the allegation is of an injury having been inflicted by a sharp weapon. The FIR records that the MLC characterises the injuries as “simple”. 11. In light of the foregoing, the parties seek quashing of the impugned FIRs. 12. It is well settled by the Supreme Court that, in appropriate circumstances, High Courts may, in the exercise of their inherent powers under Section 528 of the BNSS (corresponding to Section 482 of the CrPC), quash criminal proceedings, including those relating to non- compoundable offences, where a compromise has been reached between the accused and the complainant, provided that no overriding public 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 17/07/2026 at 11:12:18 CRL.M.C. 4564/2026 & connected matter. Page 4 of 7 interest would be adversely affected. 13. 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 17/07/2026 at 11:12:18 CRL.M.C. 4564/2026 & connected matter. Page 5 of 7 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 17/07/2026 at 11:12:18 CRL.M.C. 4564/2026 & connected matter. Page 6 of 7 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 14. Applying the principles discussed above to the present matters, this Court is of the view that the cases at hand constitute a fit occasion for the exercise of its inherent jurisdiction to quash the FIRs. The disputes arise from matrimonial discord, and it is evident that the parties have terminated their marital relationship and seek to move forward with their respective lives. The injuries sustained are also simple in nature. In such circumstances, quashing the FIRs would serve the ends of justice by allowing the parties to live in peace and harmony, rather than prolonging discord. In view of the amicable settlement reached between the parties, the likelihood of conviction is also remote. Continuation of the criminal proceedings would, therefore, serve no useful purpose and would impose an unnecessary burden on judicial resources. 15. The settlement between the parties contemplates payment of a total sum of Rs. 5,25, 000/- to the wife, of which Rs. 4,75,000/- has already been received by her, and the remaining Rs. 50,000/-, has been handed over to her in Court. There is, therefore, no impediment to granting the relief sought. 16. In view of the foregoing, the petitions are allowed. Accordingly, FIR No. 442/2015 dated 25.08.2015, registered at Police Station Jafrabad, New Delhi, under Sections 324/506/34 of the IPC [subject matter of CRL.M.C. 4564/2026], as well as FIR No. 134/2012 dated 21.05.2012, 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 17/07/2026 at 11:12:18 CRL.M.C. 4564/2026 & connected matter. Page 7 of 7 registered at Police Station Zafrabad, Delhi, under Sections 498A/406/34 of the IPC and Section 4 of the DP Act, 1961, [subject matter of CRL.M.C. 4626/2026], alongwith all consequential proceedings arising therefrom, are hereby quashed. 17. The parties shall remain bound by the terms of the settlement. 18. The petitions, alongwith the pending applications, accordingly stand disposed of. PRATEEK JALAN, J JULY 14, 2026 ‘B’/AD/ 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 17/07/2026 at 11:12:18