IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Date of decision: 12.02.2026 (Through VC)

Amanpreet Kaur @ Amanpreet Kaur Sidhu …... Petitioner(s)

V/s State of Punjab and anr.

...Respondent(s)

CORAM: HON’BLE MR. JUSTICE JASJIT SINGH BEDI Present: Mr. Tarun Singla, Advocate, for the petitioner(s).

Mr. Harkanwar Jeet Singh, AAG, Punjab.

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JASJIT SINGH BEDI, J. (Oral)

The prayer in the present petition under Section 528 BNSS is for quashing of FIR No.19 dated 16.03.2025 under Section 108 BNS, 2023 (306 IC), registered at Police Station Phool, District Bathinda (Annexure P- 1) and all subsequent proceedings arising therefrom on the basis of a compromise (Annexure P-2).

2. The learned counsel for the petitioner contends that the aforementioned FIR (Annexure P-1) had been registered on account of some misunderstandings which have been removed. In furtherance of the same, a compromise has been arrived at with the intervention of the Panchayat and respectables, a copy of which is attached as Annexure P-2. As the matter stands settled between the parties, the FIR (Annexure P-1) be quashed in the interest of justice. Reliance is placed on ‘Ashutosh Shiv and others versus State of Punjab and others 2023 NCPHHC 156537, Mohd. Imran and others State of U.T., Chandigarh and another (CRM-M-25962-2023 decided on 15.10.2024), Neha Dhiman and others versus State of Haryana and another 2023 NCPHHC 126317, Narinder Sharma, @ Narinder Singh versus State of Punjab and another (CRM-M-16283-2025 decided on 27.05.2025), Arsh Vikram Singh versus State of Punjab and others 2022(4) Law Herald 2897, Gulshan Kumar and another versus State of Punjab and others (CRM-M-19732-2021 decided on 24.03.2022) and Hardeep Singh and others versus State of Punjab and another (CRM-M-

48995-2024 decided on 18.11.2024)’.

3. The learned counsel for the State, on the other hand, contends that in view of the judgments of the Hon’ble Supreme Court in ‘Daxaben versus State of Gujarat and others 2022 AIR Supreme Court 3530, Paramjit Kaur and others versus State of Punjab and others 2025(3) CriCC 432, Kewal Singh and another versus State of Punjab 2025 NCPHHC 38662 and Neelam Devi and another versus State of Punjab and another 2022(3) RCR(Criminal) 740, an FIR under Section 306 IPC (Section 108 BNS) cannot be quashed on the basis of a compromise.

Therefore, the present petition is liable to be dismissed.

4. I have heard the learned counsel for the parties.

5. The Hon’ble Supreme Court in ‘Daxaben versus State of Gujarat and others 2022 AIR Supreme Court 3530’ held as under:

38. However, before exercising its power under section 482 of the Cr.P.C., 1973 to quash an FIR, criminal complaint and/or criminal proceedings, the High Court, as observed above, has to be circumspect and have due regard to the nature and gravity of the offence. Heinous or serious crimes, which are not private in nature and have a serious impact on society cannot be quashed on the basis of a compromise between the offender and the complainant and/or the victim. Crimes like murder, rape, burglary, dacoity and even abetment to commit suicide are neither private nor civil in nature. Such crimes are against the society. In no circumstances can prosecution be quashed on compromise, when the offence is serious and grave and falls within the ambit of crime against society.

39. Orders quashing FIRs and/or complaints relating to grave and serious offences only on basis of an agreement with the complainant, would set a dangerous precedent, where complaints would be lodged for oblique reasons, with a view to extract money from the accused. Furthermore, financially strong offenders would go scot free, even in cases of grave and serious offences such as murder, rape, brideburning, etc. by buying off informants/complainants and settling with them. This would render otiose provisions such as Sections 306, 498A, 304B etc. incorporated in the IPC as a deterrent, with a specific social purpose.

40. In Criminal Jurisprudence, the posi