CRL.M.C. 4040/2026 & CRL.M.C. 9179/2025 Page 1 of 6 $~129 & 36 Q * IN THE HIGH COURT OF DELHI AT NEW DELHI + CRL.M.C. 4040/2026 & CRL.M.A. 16371-73/2026 PRAVEEN JAIN ALIAS TINKU AND ORS. .....Petitioners Through: Ms. Ritu Sharma, Advocate. versus THE STATE GOVT OF NCT OF DELHI AND ANR .....Respondents Through: Mr. Tarang Srivastava, APP with SI Ankur. Mr. R.P. S. Sirohi, Advocate for R- 2 to 5. + CRL.M.C. 9179/2025 & CRL.M.A. 38346/2025 SHASHI BALA AND ORS .....Petitioners Through: Mr. R.P. S. Sirohi, Advocate. versus STATE GOVT OF NCT OF DELHI AND ANR .....Respondents Through: Mr. Tarang Srivastava, APP with SI Ankur. Ms. Ritu Sharma, Advocate. CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R % 21.05.2026 1. The present petitions under Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”] (corresponding to Section 482 of Criminal Procedure Code, 1973) seek quashing of two FIRs, being FIR No. 566/2022 dated 08.08.2022, for offences punishable under Sections 354/323/341/34 of the Indian Penal Code, 1860, [“IPC”] (subject matter 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 25/05/2026 at 11:35:16 CRL.M.C. 4040/2026 & CRL.M.C. 9179/2025 Page 2 of 6 of CRL.M.C. 4040/2026) and FIR No. 567/2022 dated 08.08.2022 for offences punishable under Sections 323/341/34 of the IPC (subject matter of CRL.M.C. 9179/2025), alongwith all consequential proceedings emanating therefrom, on the basis of settlement arrived at between the parties. Both FIRs were registered at Police Station Jafrabad, Delhi. 2. Issue notice. Mr. Tarang Srivastava, learned Additional Public Prosecutor, accepts notice on behalf of the State in both petitions. Mr. R.P.S. Sirohi, learned counsel, accepts notice on behalf of respondent Nos. 2 to 5 in CRL.M.C. 4040/2026. Ms. Ritu Sharma, learned counsel, accepts notice on behalf of respondent No. 2 in CRL.M.C. 9179/2025. 3. Some of the parties are present in Court, while others are appearing on video conference. All have been duly identified by the learned counsel and the Investigating Officer. 4. FIR No. 566/2022, being the subject matter of CRL.M.C. 4040/2026, was registered upon a complaint by the complainant, who alleged that his daughter was being teased and subjected to abuses by certain local boys while returning home. When the complainant and his sons confronted the petitioners, they allegedly assaulted them, causing injuries. 5. On the other hand, FIR No. 567/2022, which is the subject matter of CRL.M.C. 9179/2025, was registered upon the complaint by respondent No. 2 therein, who stated that on 06.08.2022, he saw two boys hurling abuses in the street, accompanied by a girl. When he objected to their abusive behaviour, the petitioners, allegedly assaulted him, due to which he sustained injuries. 6. The chargesheet has not yet been filed in either case. 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 25/05/2026 at 11:35:16 CRL.M.C. 4040/2026 & CRL.M.C. 9179/2025 Page 3 of 6 7. I am informed that the injuries sustained in both cases were simple in nature and there were no allegations of use of any sharp objects or fire arm. 8. During the pendency of the proceedings, the parties entered into settlement agreements dated 29.11.2025. 9. Affidavits of the respective complainants, signifying their no objection to the quashing of the impugned FIRs and all consequential proceedings arising therefrom, have also been placed on record. 10. I am informed that most of the proceedings have already been resolved. The complainants in both cases state that the allegations against each other arose out of a misunderstanding stemming from a trivial neighbourhood dispute. They confirm before the Court that they have settled their disputes and do not wish to proceed with the criminal proceedings against each other. They continue to live in the same locality and wish to maintain peace. 11. In light of the aforesaid, the parties seek quashing of the impugned FIRs. 12. 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 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 25/05/2026 at 11:35:16 CRL.M.C. 4040/2026 & CRL.M.C. 9179/2025 Page 4 of 6 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.” [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 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 25/05/2026 at 11:35:16 CRL.M.C. 4040/2026 & CRL.M.C. 9179/2025 Page 5 of 6 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 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.] 13. The present matters arise from cross-FIRs lodged by neighbours, which appears to have emanated from a sudden neighbourhood dispute. The injuries sustained are simple in nature, and the parties have amicably settled their disputes, placing on record affidavits affirming the voluntary nature of the settlement and expressing no objection to quashing. In these circumstances, continuation of the proceedings would serve no useful purpose and is unlikely to result in convictions, amounting instead to an unnecessary diversion of judicial resources. This Court, therefore, considers it a fit case for exercise of inherent powers under Section 528 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 25/05/2026 at 11:35:16 CRL.M.C. 4040/2026 & CRL.M.C. 9179/2025 Page 6 of 6 of the BNSS to quash the FIRs and promote peace between the parties. 14. The petitions are therefore allowed, and FIR No. 566/2022 dated 08.08.2022 for offences punishable under Sections 354/323/341/34 of the IPC and FIR No. 567/2022 dated 08.08.2022 for offences punishable under Sections 323/341/34 of the IPC, both lodged at Police Station Jafrabad, Delhi, 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 MAY 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 25/05/2026 at 11:35:16