LALIT SINGH & ORS. v. THE STATE (NCT OF DELHI) & ORS.
CRL.M.C./7219/2026 · 2026-09-25
Mini Pushkarna
body2026
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Judgment text
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$~44 * IN THE HIGH COURT OF DELHI AT NEW DELHI %
Date of Decision: 25th September, 2026 # CNR No. DLHC010461812026 + CRL.M.C. 7219/2026 & CRL.M.A. 30131/2026
LALIT SINGH & ORS.
.....Petitioners
Through: Mr. Pranav Prakas Sharma, Adv.
Mob: 7404905856
versus
THE STATE (NCT OF DELHI) & ORS.
.....Respondents
Through: Mr. Shoaib Haider, APP for the State,
Respondent nos. 2 to 6 in person.
CORAM:
HON’BLE MS. JUSTICE MINI PUSHKARNA
MINI PUSHKARNA, J. (Oral):
1. The present petition has been filed under Section 528 Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”), corresponding to Section 482 of the Code of Criminal Procedure, 1973 (“CrPC”), seeking quashing of FIR No. 929/2017 dated 11th December, 2017, registered at Police Station (“PS”) Mukherjee Nagar, North West District, Delhi, under Sections 323/354/342/506/34 of the Indian Penal Code, 1860 (“IPC”), and its consequential proceedings, on the ground of settlement.
2. Issue notice. Notice is accepted by learned Additional Public Prosecutor (“APP”) for the State, i.e., respondent no. 1, as well as by respondent nos. 2 to 6, who are present before this Court.
3. The brief facts necessitating filing of the present petition, as culled out from the documents on record, are as follows: Digitally Signed By:HARIOM SHARMA Signing Date:29.09.2026 09:12:15 Signature Not Verified
3.1 On 11th December, 2017, FIR No. 929/2017 was registered based on a complaint by respondent nos. 2 to 6 herein. 3.2 It was alleged in the said FIR that, while one of the respondents was proceeding towards the lane where a toilet was located at Indira Vikas Colony, petitioner no. 2 deliberately struck him on the shoulder. 3.3 The altercation thereafter escalated, involving the other petitioners and respondents. The petitioners allegedly assaulted and threatened the respondents, causing them injuries. 3.4 Subsequently, the police were called, and the injured respondents were taken to Babu Jagjivan Ram Memorial Hospital for medical treatment.
4.
Learned counsel appearing for the petitioners submits that the petitioners and respondent nos. 2 to 6, being neighbours, have amicably resolved their dispute with the intervention of common friends and acquaintances, and executed a Compromise-cum-Settlement Deed dated 22nd September, 2026. 5. Attention of this Court has been drawn to Annexure P-2, i.e., the aforesaid Compromise-cum-Settlement Deed, whereby, respondent nos. 2 to 6 have agreed to record their no objection before this Court for quashing of the FIR. 6. Respondent nos. 2 to 6 are present before this Court, and are identified by the concerned Investigating Officer (“IO”). 7. The said respondents affirm that they have settled their disputes with the petitioners, and do not wish to pursue proceedings against them any further. 8. The Supreme Court has clearly held that, in certain circumstances, the High Courts, in exercise of their powers under Section 528 of the BNSS, can Digitally Signed By:HARIOM SHARMA Signing Date:29.09.2026 09:12:15 Signature Not Verified
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 by doing the same. 9. In the case of Gian Singh Versus State of Punjab and Another, (2012) 10 SCC 303, the Supreme Court has held as follows:
“xxx xxx xxx
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 Digitally Signed By:HARIOM SHARMA Signing Date:29.09.2026 09:12:15 Signature Not Verified
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. xxx xxx xxx” (Emphasis Supplied)
10. Further, in the case of Narinder Singh and Others. Versus State of Punjab and Another, (2014) 6 SCC 466, the Supreme Court has Court established guidelines for High Courts accepting settlement deeds and quashing proceedings. The relevant excerpts of the judgment read as under:
“xxx xxx xxx
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. Digitally Signed By:HARIOM SHARMA Signing Date:29.09.2026 09:12:15 Signature Not Verified
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. xxx xxx xxx” (Emphasis Supplied)
11. This Court notes that the dispute between the petitioners and respondent nos. 2 to 6 arose in the context of their relationship as neighbours. The dispute has since been amicably resolved through the execution of the Compromise-cum-Settlement Deed dated 22nd September,
2026. 12. The said Compromise-cum-Settlement Deed has been entered into voluntarily by respondent nos. 2 to 6, without any force, threat, coercion or pressure. 13. In light of the settlement arrived at between the parties and their relationship, this Court is of the considered view that continuation of the criminal proceedings would serve no useful purpose. Digitally Signed By:HARIOM SHARMA Signing Date:29.09.2026 09:12:15 Signature Not Verified
14. At this stage, learned APP appearing for the State submits that cost ought to be imposed on the petitioners. 15. Accordingly, considering the submissions made before this Court, FIR No. 929/2017, registered at PS Mukherjee Nagar, under Sections 323/342/506/34 of the IPC, and all consequential proceedings arising therefrom, are hereby quashed. 16. However, considering the fact that the FIR has been pending since the year 2017, a cost of Rs. 10,000/- is imposed upon the petitioners, payable to the Delhi High Court Advocates Welfare Trust: A/c No. 15530210002995 Bank Name: UCO Bank Branch Address: Delhi High Court IFSC: UCBA0001553
17. Let the same be deposited, within a period of four weeks, from today. 18. Proof of the same shall be filed before this Court. 19.
The parties will remain bound by the terms of the Compromise-cum- Settlement Deed dated 22nd September, 2026. 20. With the aforesaid directions, the present petition, along with the pending application, is accordingly disposed of. MINI PUSHKARNA, J SEPTEMBER 25, 2026/SK
By:HARIOM SHARMA Signing Date:29.09.2026 09:12:15