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CRL.M.C. 6571/2026 & connected matter.
$~97 & 98-Q * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010418212026 + CRL.M.C. 6571/2026 & CRL.M.A. 27450/2026 ASHWANI & ORS. .....Petitioners versus THE STATE (NCT OF DELHI) & ORS. .....Respondents # CNR No. DLHC010418272026 + CRL.M.C. 6573/2026 & CRL.M.As. 27452-53/2026 VANSHUL VASHISHT & ORS. .....Petitioners versus THE STATE (NCT OF DELHI) & ORS. .....Respondents Appearances:- Ms. Ruchika Gupta and Mr. Parvej Aalam, Advocates for petitioners in item No. 97 and for respondent Nos. 2 to 6 in item No. 98. Ms. Shivani Sharma, Advocate for petitioners in item No. 98 and for respondent Nos. 2 to 4 in item No. 97. Ms. Manjeet Arya, APP with SI Randeep, P.S. North Rohini, Delhi in item No. 97, and ASI Ravinder Kumar, P.S. North Rohini, Delhi in item No. 98.
CORAM:
HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R %
07.09.2026
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 [“CrPC”]), seeking quashing of cross-FIRs, being – [a] FIR No. 200/2026, registered under 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 14/09/2026 at 16:03:26
CRL.M.C. 6571/2026 & connected matter. Page 2 of 7 Sections 115(2)/126(2)/324(4)/3(5) of the Bharatiya Nyaya Sanhita, 2023 [“BNS”] [subject matter of CRL.M.C. 6571/2026]; and [b] FIR No. 199/2026, registered under Sections 115(2)/126(2)/110/3(5) of the BNS [subject matter of CRL.M.C. 6573/2026]. The aforesaid FIRs were registered on 20.04.2026, at Police Station North Rohini, Delhi. The petitions are founded on a compromise arrived at between the parties. 2. The parties are present in Court and have been duly identified by the Investigating Officer, as well as by their respective learned counsel. 3. At the outset, it is stated that the vakalatnamas originally filed in CRL.M.C. 6573/2026 were erroneously interchanged between the petitioners and respondent Nos. 2 to 6 therein. This statement is taken on record, with the consent of the parties on both sides. Accordingly, fresh vakalatnamas have been handed over on behalf of respondent Nos. 2 to 4 in CRL.M.C. 6571/2026, and the petitioners in CRL.M.C. 6573/2026, which are taken on record. Learned counsel for respondent Nos. 2 to 6 in CRL.M.C. 6573/2026 has also handed over a vakalatnama, which is taken on record. 4. Issue notice. Ms. Hitesh Vali, learned Additional Public Prosecutor, accepts notice on behalf of the State in both the petitions. Ms. Shivani Sharma, learned counsel, accepts notice on behalf of respondent Nos. 2 to 4 in CRL.M.C. 6571/2026. Ms. Ruchika Gupta, learned counsel, accepts notice of behalf of respondent Nos. 2 to 6 in CRL.M.C. 6573/2026. 5. The FIRs arise out of the same incident dated 20.04.2026. The accused persons in FIR No. 200/2026 [petitioners in CRL.M.C. 6571/2026] are the complainant/alleged injured persons in FIR No. 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 14/09/2026 at 16:03:26
CRL.M.C. 6571/2026 & connected matter. Page 3 of 7 199/2026 [respondent Nos. 2 to 6 in CRL.M.C. 6573/2026], and vice versa. 6. FIR No. 199/2026 was registered at the instance of respondent No.2 in CRL.M.C. 6573/2026, alleging that, while returning from a wedding with respondent Nos. 3 to 6 therein, another car overtook them recklessly and blocked their path. The driver/occupants of the said car [petitioners in CRL.M.C. 6573/2026] allegedly abused them, following which a scuffle ensued between the parties. Similarly, FIR No. 200/2026 was registered at the instance of respondent No. 2 in CRL.M.C. 6571/2026, who alleged that, while travelling with respondent Nos. 3 and 4 therein, the petitioners in CRL.M.C. 6571/2026 blocked their path, damaged their car, and abused them, leading to a scuffle. 7. The parties have since amiably resolved their disputes, as recorded in Memoranda of Understanding dated 13.08.2026. It is stated therein that the FIRs came to be registered due to the arrogance of the parties. 8. While there was some damage to the vehicle of the complainant in FIR No. 200/2026, Ms. Sharma states that the repairs were undertaken at the expense of the accused persons. Further, the complainant in FIR No. 199/2026 suffered head injuries, however, the injuries were classified as ‘simple’. He is present in Court and is represented by learned counsel, and states that there are no subsisting or lasting consequences. I am also informed that the injuries suffered by all the victims were simple in nature. 9.
Learned counsel for the parties confirm that the settlements have been entered into voluntarily, and without any coercion or undue influence. 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 14/09/2026 at 16:03:26
CRL.M.C. 6571/2026 & connected matter. Page 4 of 7
10. Affidavits of the respective complainants/victims, signifying their no-objection to the quashing of the impugned FIRs and all consequential proceedings arising therefrom, have also been placed on record. 11. In view of the aforesaid, the parties seek quashing of the impugned FIRs. 12. The Supreme Court has clearly held that, in certain circumstances, the High Courts, in exercise of their powers under Section 482 of the CrPC [corresponding to Section 528 of the BNSS], can quash criminal proceedings, even with respect to non-compoundable offences, on the ground that there is a compromise between the accused and the complainant, especially when no overarching public interest is adversely affected. 13. 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 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, 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 14/09/2026 at 16:03:26
CRL.M.C. 6571/2026 & connected matter. Page 5 of 7 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. 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 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 14/09/2026 at 16:03:26
CRL.M.C. 6571/2026 & connected matter. Page 6 of 7 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.]
14. The offences alleged in the subject FIRs arise out of a sudden altercation. As noted above, the injuries sustained by the victims were simple in nature. The allegations do not, therefore, disclose any element of heinous criminality, that would warrant the continuation of the criminal proceedings. Applying the principles laid down by the Supreme Court, it is pertinent to note that the complainants/injured persons have also 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 useful purpose, while merely adding to the burden on the justice system and causing unnecessary consumption of public resources. 15. The petitions are, therefore, allowed, and all proceedings emanating from FIR No. 200/2026 [subject matter of CRL.M.C. 6571/2026]; and FIR No. 199/2026 [subject matter of CRL.M.C. 6573/2026], both dated 20.04.2026, and registered at Police Station North Rohini, Delhi, are hereby quashed, subject to payment of costs of Rs. 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 14/09/2026 at 16:03:26
CRL.M.C. 6571/2026 & connected matter. Page 7 of 7 20,000/-, to be paid by the petitioners collectively in each of the petitions to the Delhi High Court Bar Association [A/C No. 15530110179338, IFSC No. UCBA0001553, Bank Name: UCO Bank, Branch: Delhi High Court], within two weeks from today. An affidavit of compliance shall be filed within two weeks thereafter. 16. The petitions, alongwith pending applications, accordingly stand
disposed of.
PRATEEK JALAN, J SEPTEMBER 7, 2026
“B”/KA/ 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 14/09/2026 at 16:03:26