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CRL.M.C. 5696/2026 & CRL.M.C. 3072/2025 Page 1 of 7 $~84 & 43 Q * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010358452026 + CRL.M.C. 5696/2026 & CRL.M.A. 23792/2026 RAVI @ ANDA & ORS. .....Petitioners Through: Mr. Rajat Phogat, Mr. Pradeep Yadav, Mr. Tushar Sharma, Advocate. versus STATE NCT OF DELHI AND ORS .....Respondents Through: Mr. Tarang Srivastava, APP Mr. Praveen Singh, Mr. Hashim Khan, Mr. Izhar Hashmi, Mr. Dirgesh Nandini, Advocates. SI Ritu Ras. # CNR No. DLHC010262742025 + CRL.M.C. 3072/2025 IRSHAD ALI & ORS. .....Petitioners Through: Mr. Praveen Singh, Mr. Hashim Khan, Mr. Izhar Hashmi, Ms. Durgesh Nandini, Advocates. versus STATE NCT OF DELHI & ORS. .....Respondents Through: Mr. Tarang Srivastava, APP with Mr. Abhay Saini, Advocate. Mr. Rajat Phogat, Mr. Pradeep Yadav, Mr. Tushar Sharma, Advocate. ` SI Shyam Nandan.
CORAM:
HON’BLE MR. JUSTICE PRATEEK JALAN 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 29/08/2026 at 16:20:04
CRL.M.C. 5696/2026 & CRL.M.C. 3072/2025 Page 2 of 7 O R D E R %
21.08.2026
1. The present petitions have been filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”], corresponding to Section 482 of the Code of Criminal Procedure, 1973, seeking quashing of two cross-FIRs registered at Police Station Uttam Nagar, Delhi, along with all consequential proceedings emanating therefrom, on the basis of a settlement arrived at between the parties. The first FIR, being FIR No. FIR No. 739/2021, dated 02.10.2021, was registered for offences punishable under Sections 308/34 of the Indian Penal Code, 1860 [“IPC”] [subject matter of CRL.M.C. 5696/2026], and the second FIR, being FIR No. 740/2021, dated 02.10.2021, was registered for offences punishable under Sections 308/34 of IPC [subject matter of CRL.M.C. 3072/2025]. 2. The cross-FIRs were registered in respect of the same incident, between parties who reside in the same locality. 3. FIR No. 739/2021 was registered upon the complaint of respondent No. 2 in CRL.M.C. 5696/2026, who alleged that on 30.09.2021 at about 6:30 PM, he encountered Ravi, with whom he already had animosity arising from a previous dispute. He alleged that Ravi abused and threatened him, resulting in an argument, intervened by bystanders. Later, Ravi, alongwith his associates, allegedly came to the complainant's dhaba. While others restrained him, Ravi and Manish beat him with sticks, causing injuries. The complainant's mother Zakia attempted to intervene, and was also allegedly assaulted. Neighbours who arrived subsequently were also allegedly beaten. 4. FIR No. 740/2021 was registered upon the complaint of respondent 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 29/08/2026 at 16:20:04
CRL.M.C. 5696/2026 & CRL.M.C. 3072/2025 Page 3 of 7 No. 2 in CRL.M.C. 3072/2025, who alleged that on 30.09.2021, at about 6:30 PM, while travelling on his scooter to an atta chakki, where Irshad and some others were standing on the roadside.
The complainant alleged that after he asked them to make way, Irshad abused him and subsequently struck him in the eye with a wooden plank, causing him to fall from his scooter. He further stated that his maternal uncle’s son also assaulted him. 5. Chargesheets in both cases have already been filed. In CRL.M.C. 5696/2026, the MLCs of the injured persons record simple injuries, except in the case of Saif Ali [Respondent No. 6 in CRL.M.C. 5696/2026], whose MLC records the injuries as grievous in nature. However, Saif Ali is present before this Court and states that the injuries have caused no lasting consequences and that he has since fully recovered. In CRL.M.C. 3072/2025, the MLC of the injured person records simple injuries. 6. During the pendency of the proceedings, the parties have amicably settled their disputes. In CRL.M.C. 5696/2026, a settlement has been arrived by way of a Settlement Deed dated 23.07.2026, and in CRL.M.C. 3072/2025, settlement has been arrived at by way of Settlement Deed dated 23.09.2024. 7.
Learned counsel for the parties submit that the parties have entered into a settlement voluntarily, without any coercion, undue influence, or pressure. The complainants in both cases state that the allegations against each other arose out of a misunderstanding stemming from a trivial dispute. They confirm before the Court that they have settled their disputes and do not wish to proceed with the criminal proceedings against 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 29/08/2026 at 16:20:04
CRL.M.C. 5696/2026 & CRL.M.C. 3072/2025 Page 4 of 7 each other. They continue to live in the same locality and wish to maintain peace. 8. I am informed that Zakia is another victim in FIR No. 739/2021 [subject matter of CRL.M.C. 5696/2026], but has not been made party to the petition. She is however present through video conferencing and states that she has no objection to the quashing of the impugned FIR. It is further stated that no MLC has been prepared in respect of any injuries to her. 9. Some of the parties are present in Court, while others are appearing on video conference, and they all have been identified by their learned counsel and the Investigating Officer. 10. In light of the aforesaid, the parties seek quashing of the impugned FIRs. 11. Even in the case of non-compoundable offences, the Supreme Court has held that, in appropriate cases, the Court may quash the FIR on the ground of settlement. In Gian Singh v. State of Punjab and Anr. [(2012) 10 SCC 303], the Supreme Court 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 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 29/08/2026 at 16:20:04
CRL.M.C. 5696/2026 & CRL.M.C. 3072/2025 Page 5 of 7 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.” [Emphasis supplied.] Further, in Narinder Singh and Ors. v. State of Punjab and Anr. [(2014) 6 SCC 466], 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. 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 29/08/2026 at 16:20:04
CRL.M.C. 5696/2026 & CRL.M.C. 3072/2025 Page 6 of 7 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 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.” [Emphasis supplied.]
12. The present matters arise out of cross-FIRs lodged by persons living in the same locality in relation to the same incident, which appears to have emanated from a sudden neighbourhood dispute. The MLCs of the injured persons records simple injuries, except Saif Ali. However, he has confirmed that he has since recovered, and there is no lasting consequence. No firearm or sharp objects were used in the incident. The parties have since amicably settled their disputes and have affirmed the voluntary nature of the settlement before this Court. The complainants in the respective FIRs have also affirmed the settlement and expressed their no objection to the quashing of the proceedings. 13. In these circumstances, continuation of the criminal proceedings would serve no useful purpose and is unlikely to result in a fruitful prosecution, while unnecessarily diverting judicial resources. The parties 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 29/08/2026 at 16:20:04
CRL.M.C. 5696/2026 & CRL.M.C. 3072/2025 Page 7 of 7 reside in the same neighbourhood, and the continuation of the proceedings would, in the circumstances, only serve to perpetuate animosity and friction between them.
This Court, therefore, considers the present matters to be fit cases for the exercise of its inherent jurisdiction under Section 528 of the BNSS to quash the impugned FIRs and all consequential proceedings emanating therefrom, thereby bringing quietus to the dispute and promoting peace between the parties. 14. The petitions are accordingly allowed. FIR No. 739/2021, dated 02.10.2021, registered for offences punishable under Sections 308/34 of the IPC [subject matter of CRL.M.C. 5696/2026], and FIR No. 740/2021, dated 02.10.2021, was registered for offences punishable under Sections 308/34 of IPC [subject matter of CRL.M.C. 3072/2025], alongwith all consequential proceedings emanating therefrom, are hereby quashed. 15. The parties shall remain bound by the terms of the settlement. 16. Accordingly, the petitions stand disposed of. PRATEEK JALAN, J AUGUST 21, 2026 SS/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 29/08/2026 at 16:20:04