The court may exercise its inherent powers to quash criminal proceedings when parties reach a voluntary, amicable settlement in private disputes, as continuing with the prosecution would serve no meaningful purpose and would be contrary to the interests of justice.

Headnote:(A) Bharatiya Nagarik Suraksha Sanhita, 2023 - Section 528 - Inherent powers of High Court - Quashing of criminal proceedings - Dispute between relatives - Settlement arrived at between parties - Effect of - Court finds that when parties have arrived at an amicable settlement and the chance of conviction is remote, continuing with criminal proceedings would serve no useful purpose - Ends of justice require quashing of such criminal matters to foster peace between families. (Paras 12 and 13)

Facts of the case:
Criminal proceedings were initiated following disputes between relatives, involving allegations of harassment and intimidation. The accused sought quashing of these criminal proceedings based on a voluntary and amicable settlement reached between the involved parties with the assistance of society members.

Findings of Court:
The court observed that the disputes were of a private nature and the parties had reconciled voluntarily without coercion. Given the settlement, it was deemed that further criminal prosecution would not serve any constructive goal.

Issues: Whether the court should exercise its inherent power to quash pending criminal proceedings pursuant to a voluntary settlement between the parties.

Ratio Decidendi: When criminal disputes arise out of domestic discord and parties reach a bona fide settlement, the court may exercise its inherent powers to quash criminal proceedings to secure the ends of justice and to prevent the burden of unnecessary litigation.

Result: Petitions allowed; FIRs quashed subject to payment of costs to the relevant Legal Services Authority.

Table of Content
1. parties seeking fir quashing based on amicable settlement. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10)
2. quashing firs to serve ends of justice via settlement. (Para 11 , 12 , 13)
3. disposal of petitions subject to cost payment conditions. (Para 14 , 15 , 16 , 17)

JUDGMENT :

MANOJ JAIN, J.

1. Both these petitions, being connected, have been taken up together.

2. Petitioners, in both the cases, seek quashing of respective FIRs on the basis of amicable settlement between the parties.

3. The parties are closely related to one another.

4. CRL.M.C. 3869/2026 relates to FIR No.527/2021 dated 23.11.2021 which was registered at P.S. Kirti Nagar on the basis of statement made by daughter-in-law of petitioner No.3-Tajinder Kaur. As per the allegations appearing in the abovesaid FIR, she claimed that the accused persons had caught hold of her and threatened her. When her husband came to her rescue and confronted them, he was also not spared and was threatened to be eliminated. He was also told that his wife i.e. respondent No.2 would be sexually assaulted. Charge-sheet has already been filed, albeit, charges are yet to be framed.

5. The other connected case i.e. CRL.M.C. 3895/2026 relates to FIR 528/2021 registered on the same day with the same police station. Respondent No.2 therein alleged that her nephew-Satinder Singh, his wife and others were abusing her as well as her other relatives and entered into scuffle with them and her chunni was pulled by them and there was an attempt to tear her clothes. Respondent No.2 is paternal aunt of petitioner No.2. Charge-sheet has already been filed.

6. Fact, however, remains that the matters have been amicably settled between the parties with the intervention of respective members of the society and the parties have agreed to resolve all their disputes and, therefore, the concerned complainants have no objection if the respective FIRs are quashed.

7. It is in the abovesaid backdrop that quashing of the FIRs is being sought.

8. Copy of Compromise Deed dated 25.04.2026 is on record.

9. I.O. is also present in Court and concerned complainants are also present with their respective counsel and complainants have been duly identified by the IO and respective counsel.

10. When asked, complainant/respondent No.2 reiterated the terms of the settlement and submitted that they have entered into the abovesaid settlement out of their own free will, without any coercion and influence from any corner whatsoever and therefore, they would have ‘no objection’ if the respective FIRs are quashed.

11. Heard.

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

13. Accordingly, exercising inherent powers vested in this Court under Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023, it is deemed appropriate to quash the instant FIRs.

14. Consequently, to secure the ends of justice, FIR Nos. 527/2021 and 528/2021, both dated 23.11.2021 and registered at Police Station Kirti Nagar, along with all consequential proceedings arising therefrom, are, hereby, quashed subject to petitioners depositing total cost of Rs. 30,000/-, for each case, in the account of District Legal Services Authority (DLSA) West District, Tis Hazari Court, Delhi within four weeks.

15. Proof of deposit of the cost as well as Original affidavits of the settlement deed of the parties be submitted to the learned Trial Court within further two weeks.

16. The present petitions stand disposed of in aforesaid terms.

17. Pending applications also stand disposed of.

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Judicial Analysis