Habibur Rehman vs The State (Nct Of Delhi) & Anr on 19 May, 2026

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    Delhi High Court – Orders

    Habibur Rehman vs The State (Nct Of Delhi) & Anr on 19 May, 2026

    Author: Prateek Jalan

    Bench: Prateek Jalan

                              $~126-Q
                              *    IN THE HIGH COURT OF DELHI AT NEW DELHI
    
                              +         CRL.M.C. 3973/2026
                                        HABIBUR REHMAN                                                          .....Petitioner
                                                        Through:                          Mr. Prince Bansal, Adv. alongwith
                                                                                          Petitioners in person
    
                                                                      versus
    
                                        THE STATE (NCT OF DELHI) & ANR.          .....Respondent
                                                      Through: Mr. Hitesh Vali, APP with Mr.
                                                                Mohd. Navaed, Adv.
                                                                SI Avinash Kumar, PS Anand
                                                                Vihar
    
                              CORAM:
                              HON'BLE MR. JUSTICE PRATEEK JALAN
    
                                                                      ORDER
    

    % 19.05.2026

    1. The petitioner has filed the present petition under Section 528 of
    the Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”] (corresponding
    to Section 482 of the Code of Criminal Procedure, 1973 [“CrPC“]),
    seeking quashing of FIR No. 0117/2025 dated 12.03.2025, registered at
    Police Station Anand Vihar, District Shahdara, under Sections
    406
    /420/120B of the Indian Penal Code, 1860 [“IPC“], alongwith all
    consequential proceedings arising therefrom, on the ground that the
    dispute between the parties has been amicably settled.

    SPONSORED

    2. Issue notice. Mr. Hitesh Vali, learned Additional Public
    Prosecutor, accepts notice on behalf of the State. Respondent No. 2 is
    present in person and accepts notice. She further states that she does not

    CRL.M.C. 3973/2026 Page 1 of 7

    This is a digitally signed order.

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    wish to seek any legal assistance.

    3. The petitioner is present in Court and is identified by his learned
    counsel as well as the Investigating Officer. Respondent No. 2 is also
    present in Court and is identified by the Investigating Officer.

    4. Two other persons have been named as accused in the subject FIR,
    being the daughter and son-in-law of the petitioner herein. They are
    present in Court and have been identified by the Investigating Officer. On
    the oral request of Mr. Prince Bansal, learned counsel for the petitioner,
    they have been impleaded as petitioner Nos. 2 and 3, respectively, in the
    present proceedings. An amended memo of parties to that effect has been
    handed over during the course of the day and is taken on record.

    5. The petition is taken up for disposal with the consent of learned
    counsel for the parties.

    6. The impugned FIR was lodged at the instance of respondent No. 2
    in relation to M/s Lans Castle, a partnership firm constituted under a
    Partnership Deed dated 22.07.2011 between respondent No. 2 and
    petitioner No. 1 for running a hotel business. It is alleged that under a
    Supplemental Deed dated 25.05.2012 and a Mutual Agreement dated
    21.10.2015, the land and hotel assets were brought into the common pool
    of partnership property and were jointly owned and operated by the
    petitioner No.1 and respondent No.2. The complainant alleges that in
    furtherance of a conspiracy, the accused persons unlawfully ousted her
    from the partnership and, in 2019, fraudulently obtained registration of
    the hotel trademark as a sole proprietorship in the name of petitioner No.
    3 herein. It is further alleged that in 2020, a cash credit facility was
    obtained from the State Bank of India on the basis of misrepresentation,

    CRL.M.C. 3973/2026 Page 2 of 7

    This is a digitally signed order.

    The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.
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    followed by attempts to enhance the credit facility and wrongful dealing
    with the mortgage and title deeds, which ultimately resulted in closure of
    the hotel operations in 2020.

    7. During the pendency of the present proceedings, the parties have
    amicably settled their disputes, as recorded in a Memorandum of
    Understanding dated 28.04.2026 [“MoU”]. Under the said settlement, it
    has been agreed that petitioner No. 1 shall pay a sum of Rs. 2,35,00,000/-
    to respondent No. 2 towards full and final settlement of all claims arising
    out of the dispute.

    8. Respondent No. 2 confirms that she has received the entire
    settlement amount in terms of the MoU, and states that all disputes
    between her and the accused persons, i.e., the petitioners herein, stand
    fully and finally settled. She further submits that she has no surviving
    grievance against them and does not wish to pursue the present
    proceedings any further. Her statement to this effect has been recorded in
    Court today.

    9. In light of the aforesaid, the parties seek quashing of the impugned
    FIR.

    10. The Supreme Court has consistently held that, in appropriate cases,
    the High Courts, in exercise of their inherent powers under Section 482 of
    the Code of Criminal Procedure, 1973 (corresponding to Section 528 of
    the BNSS), may quash criminal proceedings even in respect of non-
    compoundable offences, where the parties have arrived at a genuine
    settlement, particularly when the continuation of such proceedings would
    not serve any larger public interest. Reference in this regard may be made

    CRL.M.C. 3973/2026 Page 3 of 7

    This is a digitally signed order.

    The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.
    The Order is downloaded from the DHC Server on 22/05/2026 at 21:37:25
    to the judgment in Gian Singh v. State of Punjab and Anr.1, which held as
    follows:

    “58. Where the High Court quashes a criminal proceeding having
    regard to the fact that the dispute between the offender and the victim
    has been settled although the offences are not compoundable, it does
    so as in its opinion, continuation of criminal proceedings will be an
    exercise in futility and justice in the case demands that the dispute
    between the parties is put to an end and peace is restored; securing
    the ends of justice being the ultimate guiding factor. No doubt, crimes
    are acts which have harmful effect on the public and consist in
    wrongdoing that seriously endangers and threatens the well-being of
    the society and it is not safe to leave the crime-doer only because he
    and the victim have settled the dispute amicably or that the victim has
    been paid compensation, yet certain crimes have been made
    compoundable in law, with or without the permission of the court. In
    respect of serious offences like murder, rape, dacoity, etc., or other
    offences of mental depravity under IPC or offences of moral turpitude
    under special statutes, like the Prevention of Corruption Act or the
    offences committed by public servants while working in that capacity,
    the settlement between the offender and the victim can have no legal
    sanction at all. However, certain offences which overwhelmingly and
    predominantly bear civil flavour having arisen out of civil, mercantile,
    commercial, financial, partnership or such like transactions or the
    offences arising out of matrimony, particularly relating to dowry, etc.
    or the family dispute, where the wrong is basically to the victim and
    the offender and the victim have settled all disputes between them
    amicably, irrespective of the fact that such offences have not been
    made compoundable, the High Court may within the framework of
    its inherent power, quash the criminal proceeding or criminal
    complaint or FIR if it is satisfied that on the face of such settlement,
    there is hardly any likelihood of the offender being convicted and by
    not quashing the criminal proceedings, justice shall be casualty and
    ends of justice shall be defeated. The above list is illustrative and not
    exhaustive. Each case will depend on its own facts and no hard-and-

    2

    fast category can be prescribed.”

    Further, in Narinder Singh and Ors. v. State of Punjab and Anr.3, the
    Supreme Court has also laid down guidelines for High Courts while

    1
    (2012) 10 SCC 303.

    2

    Emphasis supplied.

    3

    (2014) 6 SCC 466.

    CRL.M.C. 3973/2026 Page 4 of 7

    This is a digitally signed order.

    The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.
    The Order is downloaded from the DHC Server on 22/05/2026 at 21:37:25
    accepting settlement deeds between parties and quashing the proceedings.
    The relevant observations in the said decision read as under:

    “29. In view of the aforesaid discussion, we sum up and lay down the
    following principles by which the High Court would be guided in
    giving adequate treatment to the settlement between the parties and
    exercising its power under Section 482 of the Code while accepting the
    settlement and quashing the proceedings or refusing to accept the
    settlement with direction to continue with the criminal proceedings:

    29.1. Power conferred under Section 482 of the Code is to be
    distinguished from the power which lies in the Court to compound the
    offences under Section 320 of the Code. No doubt, under Section 482
    of the Code, the High Court has inherent power to quash the criminal
    proceedings even in those cases which are not compoundable, where
    the parties have settled the matter between themselves. However, this
    power is to be exercised sparingly and with caution.
    29.2. When the parties have reached the settlement and on that basis
    petition for quashing the criminal proceedings is filed, the guiding
    factor in such cases would be to secure:

    (i) ends of justice, or

    (ii) to prevent abuse of the process of any court.

    While exercising the power the High Court is to form an opinion on
    either of the aforesaid two objectives.

    29.3. Such a power is not to be exercised in those prosecutions which
    involve heinous and serious offences of mental depravity or offences
    like murder, rape, dacoity, etc. Such offences are not private in nature
    and have a serious impact on society. Similarly, for the offences
    alleged to have been committed under special statute like the
    Prevention of Corruption Act or the offences committed by public
    servants while working in that capacity are not to be quashed merely
    on the basis of compromise between the victim and the offender.
    29.4. On the other hand, those criminal cases having overwhelmingly
    and predominantly civil character, particularly those arising out of
    commercial transactions or arising out of matrimonial relationship
    or family disputes should be quashed when the parties have resolved
    their entire disputes among themselves.

    29.5. While exercising its powers, the High Court is to examine as to
    whether the possibility of conviction is remote and bleak and
    continuation of criminal cases would put the accused to great
    oppression and prejudice and extreme injustice would be caused to
    4
    him by not quashing the criminal cases.”

    4

    Emphasis supplied.

    CRL.M.C. 3973/2026 Page 5 of 7

    This is a digitally signed order.

    The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.
    The Order is downloaded from the DHC Server on 22/05/2026 at 21:37:25

    11. The present case essentially arises out of disputes pertaining to a
    long-standing commercial partnership concerning M/s Lans Castle.
    Although the FIR has been registered under Sections 406/420/120B IPC,
    the core of the controversy relates to inter se issues concerning
    management, proprietary rights, and financial dealings between the
    parties, which are predominantly contractual and civil in nature.
    Significantly, during the pendency of the proceedings, the parties have
    voluntarily resolved all disputes through a MoU, pursuant to which a
    monetary settlement has been arrived at in favour of respondent No. 2.

    12. Respondent No. 2 has unequivocally acknowledged receipt of the
    entire settlement amount and has stated that she has no surviving
    grievance against the petitioners, with her statement to that effect having
    been recorded before this Court. In view of the disputes between the
    parties having been voluntarily and finally settled, the continuation of
    criminal proceedings would not serve any meaningful purpose, as the
    likelihood of conviction is remote. The dispute does not involve any
    element of heinous criminality, moral turpitude, or offences having grave
    or serious societal impact, and is essentially private and commercial in
    nature. In such circumstances, where the matter is predominantly inter se
    between the parties and does not implicate any overriding public interest,
    it would be appropriate for this Court to exercise its inherent jurisdiction
    under Section 528 of the BNSS to prevent abuse of the process of law and
    to secure the ends of justice.

    13. In view of the aforesaid, the petition is allowed. Consequently, FIR
    No. 0117/2025 dated 12.03.2025, registered at Police Station Anand
    Vihar, District Shahdara, under Sections 406/420/120B of IPC, alongwith

    CRL.M.C. 3973/2026 Page 6 of 7

    This is a digitally signed order.

    The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.
    The Order is downloaded from the DHC Server on 22/05/2026 at 21:37:25
    all consequential proceedings arising therefrom, is hereby quashed.

    14. The parties shall remain bound by the terms of the settlement.

    15. The petition, alongwith pending applications, accordingly, stands
    disposed of.

    PRATEEK JALAN, J
    MAY 19, 2026
    tg/SD/

    CRL.M.C. 3973/2026 Page 7 of 7

    This is a digitally signed order.

    The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.
    The Order is downloaded from the DHC Server on 22/05/2026 at 21:37:25



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