CRL.M.C. 4391/2026 $~66 Q * IN THE HIGH COURT OF DELHI AT NEW DELHI + CRL.M.C. 4391/2026 & CRL.M.A. 17803/2026 TANVIR SINGH .....Petitioner Through: Ms. Mudita Arora, Advocate alongwith Petitioner in Person (VC). versus STATE NCT OF DELHI, & ANR. .....Respondent Through: Mr. Hitesh Vali, APP for State. Mr. Aryan Sharma, Advocate for R-2 alongwith R-2 in Person (VC). CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R % 16.07.2026 1. The present petition has been filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”] (corresponding to Section 482 of the Code of Criminal Procedure, 1973 [“CrPC”]), seeking the quashing of FIR No. 104/2026 dated 21.04.2026, registered under Sections 318(4) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 [“BNS”] at Police Station Kishan Garh, District South West, Delhi, alongwith all consequential proceedings arising therefrom, on the ground that the parties have amicably settled their disputes. 2. Issue notice. Mr. Hitesh Vali, learned Additional Public Prosecutor, accepts notice on behalf of the State. Mr. Aryan Sharma, learned counsel, accepts notice on behalf of respondent No. 2. 3. The petitioner is present through video conference and has been identified by his learned counsel. Respondent No. 2 is also present through video conference and has been identified by her learned counsel. 4. With the consent of learned counsel for the parties, the petition is 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 20/07/2026 at 11:18:18 CRL.M.C. 4391/2026 taken up for hearing. 5. As per the allegations in the present FIR, the complainant, who is stated to be the wife of the petitioner, alleged that the petitioner, in conspiracy with the owners, employees and other associates of Progfin Empowering Progress, fraudulently misused her signatures and identity documents, including those pertaining to M/s Alfa Global Technology, a partnership firm in which both the complainant and the petitioner are partners, to procure a loan of Rs. 1 crore in her name without her knowledge or consent. It is further alleged that, in the course of the matrimonial disputes between the parties, the complainant was coerced into signing certain documents, which were subsequently misused to obtain the aforesaid loan. According to the complainant, she had neither applied for the loan nor executed any loan documents, nor had she ever visited the lender’s office. Alleging that the petitioner and the other accused persons had acted in furtherance of a criminal conspiracy to forge documents and cheat her, the present FIR came to be registered. 6. Although the offences alleged in the present FIR are compoundable, the matter is still under investigation and the chargesheet has not yet been filed. Ms. Mudita Arora, learned counsel for the petitioner, submits, on instructions, that the complaint was lodged and, shortly thereafter, the parties amicably resolved their disputes by executing a Settlement Deed dated 20.04.2026. It is submitted that the settlement was arrived at prior to the registration of the present FIR, which came to be registered on 21.04.2026. It is further submitted that, thereafter, the petitioner was issued a notice dated 12.05.2026 under Section 35(3) of BNSS, directing him to join the investigation on 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 20/07/2026 at 11:18:18 CRL.M.C. 4391/2026 16.05.2026. 7. The parties have since amicably resolved all their disputes, as recorded in the Settlement Deed dated 20.04.2026. Under the terms thereof, they agreed to dissolve their matrimonial relationship and comprehensively settle all inter se matrimonial, civil, financial and business disputes. It was, inter alia, agreed that respondent No. 2 would stand retired as a partner of M/s Alfa Global Technology with effect from 22.05.2025. The petitioner further undertook to assume responsibility for repayment of the outstanding overdraft facility of approximately Rs.3.75 crores secured against Plot No. 569, M.K. Technology Park, Banur, including by furnishing a security cheque in respect thereof, and to discharge the outstanding loans and liabilities of M/s Alfa Global Technology and the other entities specified in the Settlement Deed. The settlement also records that the alleged loan of approximately Rs.1.10 crores relating to the immovable property was being serviced by the petitioner, alongwith other consequential obligations relating to the underlying property. 8. The petitioner further undertook to indemnify respondent No. 2 against all past, present and future liabilities arising out of the aforesaid financial obligations. It was further agreed that, upon due fulfilment of the obligations undertaken by the parties under the Settlement Deed, respondent No. 2 shall have no liability, right, title, interest or role whatsoever in the firms specified therein. The Settlement Deed was also to form an integral part of the parties’ mutual consent divorce proceedings and to constitute a full and final settlement of all disputes between them. 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 20/07/2026 at 11:18:18 CRL.M.C. 4391/2026 9. In view of the aforesaid settlement, the parties jointly seek quashing of the present FIR and all consequential proceedings arising therefrom. 10. Learned counsel appearing for the parties submit that the settlement has been arrived at voluntarily, out of the parties’ own free will, and without any coercion, undue influence or pressure. 11. It is well settled that, in appropriate cases, the High Court may, in exercise of its inherent powers under Section 528 of BNSS (corresponding to Section 482 of CrPC), quash criminal proceedings on the basis of a settlement between the parties, even where the offences are non-compoundable, provided that no overriding public interest is adversely affected. In this regard, reference may be made to the decision of the Supreme Court in Gian Singh v. State of Punjab and Anr.1, wherein it was 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 1 (2012) 10 SCC 303. 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 20/07/2026 at 11:18:18 CRL.M.C. 4391/2026 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 and Ors. v. State of Punjab and Anr.3, the 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 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 20/07/2026 at 11:18:18 CRL.M.C. 4391/2026 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 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 allegations in the present FIR arise out of disputes between the petitioner and respondent No. 2 in the backdrop of their matrimonial relationship and their interconnected financial and business dealings. Although the allegations attract the provisions of Sections 318(4) of the BNS (corresponding to Section 420 of the Indian Penal Code, 1860), the controversy is, in substance, rooted in private disputes concerning the parties’ financial arrangements, and does not disclose any element of grave criminality or overriding public interest warranting the continuation of the criminal process. Significantly, the parties have comprehensively resolved all their inter se matrimonial, civil, financial and business disputes by executing the Settlement Deed dated 20.04.2026, the terms whereof also allocate responsibility for the liabilities forming the genesis of the present proceedings. 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 20/07/2026 at 11:18:18 CRL.M.C. 4391/2026 13. Respondent No. 2 has affirmed before this Court that the settlement has been entered into voluntarily, of her own free will, and without any coercion or undue influence. In these circumstances, the possibility of securing a conviction is remote and bleak, and the continuation of the criminal proceedings would serve no meaningful purpose, but would merely result in an unnecessary expenditure of judicial time and public resources. 14. Respondent No. 2 further confirms that she has received the entire settlement amount in terms of the Settlement Deed and that no amount remains due or payable thereunder. There is, accordingly, no impediment to the grant of the relief sought in the present petition. 15. Having regard to the aforesaid, the present petition is allowed. Consequently, FIR No. 104/2026 dated 21.04.2026, registered under Sections 318(4) and 3(5) of BNS at Police Station Kishan Garh, District South West, Delhi, alongwith all consequential proceedings arising therefrom, is hereby quashed. 16. The parties shall remain bound by the terms of the settlement. 17. The petition, alongwith pending application, accordingly, stands disposed of. PRATEEK JALAN, J JULY 16, 2026 ‘pv’/SD/ 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 20/07/2026 at 11:18:18