1. Criminal misc. petition to quash FIR for offences under Sections 419, 420, 467, 468, 471 & 120B IPC. (Para 2 )
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2026 Supreme(Raj) 586
HIGH COURT OF JUDICATURE FOR RAJASTHAN, BENCH AT JAIPUR
ANIL KUMAR UPMAN, J.
Ganesh Narayan Yadav, S/o. Nanuram Yadav - Petitioner
Versus
State Of Rajasthan, Through The Public Prosecutor – Respondent
S.B. Criminal Miscellaneous (Petition) No. 6018 of 2025
Decided On : 06-03-2026
Advocates Appeared:
For the Petitioner: Ms. Vaishnavi for Mr. Ashvin Garg
For the Respondent: Mr. Vijay Singh Yadav, PP, Mr. Vishnu Kumar Sharma, for complainant.
For the Petitioner: Ms. Vaishnavi for Mr. Ashvin Garg
For the Respondent: Mr. Vijay Singh Yadav, PP, Mr. Vishnu Kumar Sharma, for complainant.
An FIR for cheating and forgery can be quashed if the dispute is civil/personal, the parties have amicably settled, the complainant does not wish to pursue the case, and the accused has no criminal antecedents.
Headnote:(A) Bharatiya Nagarik Suraksha Sanhita, 2023 - Section 528 - Indian Penal Code, 1860 - Sections 419, 420, 467, 468, 471 and 120B - Quashing of FIR - Dispute of civil and personal nature - Compromise reached between parties - Absence of criminal antecedents - Where the dispute is settled amicably and the complainant does not wish to pursue the matter, and there are no criminal antecedents against the accused, the FIR is liable to be quashed. (Para 5)
Facts of the case:
An application was filed to quash an FIR registered for offences involving cheating, forgery, and conspiracy. It was contended that the dispute between the parties was purely civil and personal in nature. During the pendency of the investigation, the parties entered into a compromise, and the complainant expressed a desire not to pursue the FIR. The petitioner further stated that there were no criminal antecedents against them.
Findings of Court:
The court observed that the parties had resolved their dispute amicably and the complainant did not dispute the factum of the compromise. The court found that the case was covered by established legal principles regarding the quashing of proceedings in the event of a settlement between the parties.
Issues: Whether an FIR involving offences of cheating and forgery can be quashed on the grounds of a compromise when the dispute is civil in nature and the accused has no criminal antecedents.
Ratio Decidendi: When a dispute is purely civil and personal, and the parties have reached an amicable settlement during the investigation, and the accused has no criminal antecedents, further proceedings in the FIR are considered fruitless and the FIR is liable to be quashed.
Result: Criminal Misc. Petition allowed; FIR and all subsequent proceedings quashed and set aside.
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Table of Contents
2. Petitioner argued dispute is civil and personal; parties settled amicably. Complainant did not dispute compromise. (Para 3 , 4 )
3. Court noted parties resolved dispute amicably, no criminal antecedents, and compromise made further proceedings fruitless. (Para 5 )
4. FIR can be quashed based on compromise following principles in Gian Singh and Choudhary Bhajan Lal. (Para 5 )
5. Petition allowed; FIR and all subsequent proceedings quashed and set aside. Applications disposed of. (Para 6 , 7 )
6. Can an FIR be quashed based on a compromise between parties?
Yes, the court held that when parties settle amicably and there are no criminal antecedents, the FIR can be quashed. (Para 5 , 6 )
7. What principles govern quashing of FIR on compromise?
The court relied on the principles in Gian Singh and Choudhary Bhajan Lal, requiring the dispute to be settled and proceedings fruitless. (Para 5 )
8. What is the effect of compromise on criminal proceedings?
The compromise makes further proceedings fruitless, and the court can quash the FIR and all subsequent proceedings. (Para 3 , 5 , 6 )
Order :
ANIL KUMAR UPMAN, J.
1. Parties are present in person and they have been duly identified by their respective counsel.
2. By way of this criminal misc. petition under Section 528 BNSS, the accused-petitioner has approached this Court with a Muhana, District Jaipur City (South) for the offences punishable under Sections 419, 420, 467, 468, 471 & 120B of IPC along with all the subsequent proceedings arising out thereof.
3. Learned counsel for the petitioner submits that perusal of the FIR would reveal that the dispute between the parties is purely of civil and personal nature. Counsel submits that during pendency of the investigation, the petitioner has entered into a compromise with the complainant and the complainant does not want to pursue the impugned FIR. It is submitted that now, parties have settled their dispute amicably. It is submitted that due to compromise, further proceedings in the aforesaid FIR are fruitless. The written compromise has been annexed with this petition. It is further submitted that there are no criminal antecedents against the petitioner.
4. Learned counsel appearing on behalf of complainant does not dispute the factum of compromise.
5. In view of the aforesaid and considering the submissions made on behalf of the respective parties; the material made available for perusal; considering the facts that parties have resolved their dispute amicably and there are no criminal antecedents against the petitioner and also finding that the present case is wholly covered by the principle of law laid down by Hon'ble the Supreme Court in the case of Gian Singh Vs. State of Punjab & Anr-reported in 2012 Cr.L.J. (SC) 4934 and in the case of State of Haryana & Ors. Vs. Choudhary Bhajan Lal & Ors. [AIR 1992 SC 604] and as such, the aforesaid FIR is liable to be quashed in view of compromise arrived at between the parties.
6. In view of the above, this Criminal Misc. Petition is allowed District Jaipur City (South) along with all the subsequent proceedings arising out thereof, is quashed and set aside. Consequence to follow.
7. Stay application and pending application(s), if any, also stand disposed of.
