Inherent powers may be exercised to quash criminal proceedings for personal offences when parties have reached a voluntary, amicable settlement, as continuing such litigation serves no useful purpose and ensures the ends of justice are met.

Headnote:(A) Bharatiya Nagarik Suraksha Sanhita, 2023 - Section 528 - Indian Penal Code, 1860 - Sections 323, 341, 506 - Quashing of criminal proceedings - Settlement between parties - Where a compromise is reached between the parties in offences of personal nature, continuing with criminal proceedings serves no useful purpose - Inherent powers of the court may be exercised to secure the ends of justice and to prevent abuse of the process of law. (Paras 10, 11, 12)

Facts of the case:
The petitioner sought the quashing of an FIR registered for offences of voluntarily causing hurt, wrongful restraint, and criminal intimidation, citing a settlement deed executed between the parties. The respondent appeared before the designated authority and confirmed the settlement was entered into voluntarily, without coercion, and expressed a desire to discontinue the prosecution to maintain peace in the local neighborhood.

Findings of Court:
The court observed that in view of the amicable settlement arrived at between the parties, the continuation of criminal proceedings would be futile and detrimental to the interests of justice. The settlement effectively resolves the grievances between the affected parties.

Issues: Whether the inherent powers of the court should be exercised to quash an FIR for criminal offences where the parties have reached a voluntary and amicable settlement.

Ratio Decidendi: The court is empowered to quash criminal proceedings when they arise out of private disputes and the parties have resolved their differences, as such action prevents the waste of the state's time and resources while promoting peace and societal harmony.

Result: Petition allowed; FIR and all consequential proceedings emanating therefrom quashed subject to the petitioner depositing costs.

Table of Content
1. factual basis of the fir. (Para 1 , 2 , 3 , 4)
2. voluntary settlement between parties. (Para 5 , 6 , 7 , 8)
3. inherent power to quash settled disputes. (Para 9 , 10 , 11)
4. final order of quashing with cost conditions. (Para 12 , 13)

JUDGMENT :

MANOJ JAIN, J.

1. Petitioner herein seeks quashing of FIR No. 0870/2017 dated 11.11.2017, registered at Police Station Mehrauli, for commission of offences under Sections 323/341/506 IPC, along with all consequential proceedings arising therefrom, on the basis of compromise arrived at between the parties.

2. The abovesaid FIR was registered on the basis of report lodged by Rahul Dhaka (respondent No.2) and in his such complaint, he claimed that when he was present near Dargah School, Mehrauli on 09.11.2017, accused-Paramjeet Singh Gandas (petitioner herein) caught hold of him and gave him fist blows and also kicked him and threatened to eliminate him. When the complainant tried to leave the spot, he was stopped and slapped.

3. It was in the abovesaid backdrop of the allegations that the abovesaid FIR was registered.

4. The charge-sheet has already been filed and the case is at the stage of Prosecution Evidence.

5. Quashing is being sought on the basis of settlement.

6. Copy of the Settlement Deed dated 11.02.2026 is on record which is found to be signed by both the parties.

7. Respondent No.2 is present in Court and he has been duly identified by his counsel as well as I.O.

8. When asked, respondent No.2 submitted that the parties are residing in the same neighbourhood and since the accused-petitioner has apologized to him and since he has already forgiven him, he does not want to pursue with the abovesaid matter in any manner whatsoever. He submits that he has entered into the abovesaid settlement out of his own free will, without any coercion and influence from any corner whatsoever and therefore, he would have ‘no objection’ if FIR in question is quashed.

9. Heard.

10. In view of the settlement arrived at between the parties, continuing with criminal proceedings would serve no useful purpose.

11. Accordingly, exercising inherent powers vested in this Court under Section 528 of the BNSS, it is deemed appropriate to quash the instant FIR.

12. Consequently, to secure ends of justice, FIR No. 0870/2017 dated 11.11.2017, registered at Police Station Mehrauli, for commission of offences under Sections 323/341/506 IPC, with all consequential proceedings emanating therefrom, are hereby, quashed subject to petitioner depositing cost of Rs. 15,000/- with Delhi High Court Legal Services Committee (DHCLSC) within four weeks from today. Proof of deposit and original affidavits of the parties be submitted to the learned Trial Court within further two weeks.

13. The present petition stands disposed of in aforesaid terms.

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