Delhi High Court Quashes FIR Against M.K. Stephen, Imposes Conditional Community Service

In a significant exercise of its inherent powers, the Delhi High Court has quashed an FIR registered against M.K. Stephen and a co-accused for an alleged assault between friends, making the relief conditional upon community service and payment of costs. Justice Prateek Jalan, while allowing the petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), observed that the continuation of criminal proceedings would serve no meaningful purpose and would only perpetuate discord.

The Quarrel That Led to an FIR

The case originated from an incident on March 9, 2025, when the petitioner, M.K. Stephen, and co-accused Keke Yambem allegedly forcibly entered a rented flat in Mahavir Enclave at around 5 AM. According to the complainant, Stephen assaulted his friend with kicks and punches, causing him to fall headfirst onto a kitchen slab and sustain a head injury. A medico-legal certificate recorded the injury as dangerous, but the FIR did not allege the use of any firearm or sharp weapon.

The dispute, however, was short-lived. Within weeks, the parties executed a Settlement Deed on March 24, 2025, and the investigation subsequently culminated in a chargesheet. During the argument on charge, the Sessions Court dropped the charge under Section 110 of the Bharatiya Nyaya Sanhita (BNS), remanding the matter to the Magistrate's Court for trial.

Settlement Brings Parties Together

The petition for quashing was filed with the consent of all parties. Counsel for the petitioner and the co-accused submitted that the settlement was voluntary, without coercion or undue influence. The complainants—Respondent Nos. 2 and 3—appeared in court and affirmed the settlement, stating they had no subsisting grievance. Respondent No. 3 further informed the court that he had fully recovered from his injury with no lasting consequences.

The court noted that the parties remained friends and that the dispute arose out of a quarrel between friends. "The parties have amicably resolved their differences within a short period of the registration of the FIR," the court observed.

Legal Framework: Quashing Despite Non-Compoundable Offences

Justice Jalan relied on the principles laid down by the Supreme Court in Gian Singh v. State of Punjab and Narinder Singh v. State of Punjab , which empower High Courts to quash criminal proceedings even for non-compoundable offences when a genuine settlement exists, provided it does not adversely affect public interest. The court found that the present case—arising from a personal quarrel with no allegations of a sharp weapon or firearm, and where the grievous hurt charge had been dropped—fell within the ambit of such exceptional circumstances.

Key Observations

"The dispute between the parties arose out of a quarrel between friends."

"In these circumstances, continuation of the criminal proceedings would serve no meaningful purpose and would only perpetuate discord and animosity between parties."

"The likelihood of the proceedings culminating in a conviction is remote, and continuation of the criminal proceedings would serve no useful purpose."

Conditional Relief: Community Service and Cost

While quashing the FIR, the court imposed conditions to ensure accountability. The petitioner and the co-accused were directed to undertake community service for six sessions of two hours each at the Regional Institute of Medical Science, Manipur. They are to report to the Medical Superintendent on September 3, 2026, and complete the service within two months. Additionally, they must collectively pay Rs. 10,000 to the Delhi High Court Bar Association Costs Account within two weeks.

Subject to compliance with these conditions, the court quashed FIR No. 173/2025 along with all consequential proceedings. The parties were directed to remain bound by the terms of the settlement.

The decision underscores the High Court's willingness to use its inherent powers to close cases where a genuine settlement restores harmony, particularly in personal disputes, while ensuring that the process does not become a tool to escape accountability entirely.