Kuldeep Gochhwal vs State Of Haryana on 7 August, 2026

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    Punjab-Haryana High Court

    Kuldeep Gochhwal vs State Of Haryana on 7 August, 2026

                         CRM-
                         CRM-M-54474-
                               54474-2025
                                                                                                                              1
    
    
    
    
                         241
                                IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
    
                                                                CRM-
                                                                CRM-M-54474-
                                                                      54474-2025
    
                         Kuldeep Gochhwal
                                                                                                                 .Petitioner
                                                                                                                ....Petitioner
                                                                         versus
                         State of Haryana
                                                                                                              ....Respondent
    
                         Date of Decision: August 07,
                                                  07, 2026
                         Date of Uploading: August 07,
                                                   07, 2026
    
                         CORAM:            HON'BLE MR. JUSTICE SUMEET GOEL
    
                         Present:-
                         Present:          Mr. Rishilal, Advocate for the petitioner
                                           (presence
                                            presence marked through video-
                                                                     video-conferencing
                                                                            conferencing).
    
                                           Mr. Deepak Kumar Grewal, DAG Haryana.
    
                                                                         *****
                         SUMEET GOEL,
                                GOEL, J. (ORAL)
    

    The substantive prayer made in the petition in hand reads thus:

    “It is, therefore, most respectfully prayed that the present petition be
    allowed and FIR No.789 dated 10.12.2021 registered under sections 174 174-A
    A
    of
    IPC, registered at Police Station Karnal Civil Line, District Karnal may kindly be
    quashed.”

    2. The impugned FIR (as set out in the petition in hand) reads thus:

    SPONSORED

    “GM-88033
    88033 KF IN THE COURT OF SH. ANIL KUMAR YADAV,
    JMIC KARNAL CRL NO 3671/18, DATE OF INSTT. 28.08.18, DATE OF
    DECISION- 18.01.20 Axis Bank Ltd. a Bank, incorporated and registered under
    the Companies Act, 1956 having its Registered Office at Trishul, 3rd Floor
    Opposite Samarteswar Temple, Law Garde, Ellis Bridge, Ahmedabad Ahmedabad-308006,
    308006,
    Gujrat and one of its branch office at Mall Road, Karnal through its Authorized
    Person/ Special power of Attorney Holder Hari Om…. Complainant Versus
    KULDEEP GOCHHWAL S/O DARYAOO SINGH, R/O H.N. K 100/2,
    VRINDAWAN COLONY, BHAGWANPUR, RAIGARH, CHATTISGARH
    496001…….Accused Complaint under Section 138/142 of the Negotiable
    instruments Act (As Amended up to Date) Read With Section 357 of The Code of
    Criminal Procedure
    , 1973 Axis Bank Ltd. Vs. Kuldeep Gochwal Present: Sh.
    Amish Goel, Id. counsel for the complainant. 5832 5832-2018
    2018 Today the case was
    fixed for presencee of accused as well as for filing the list of property of accused.
    Statement of Tamili/police official to the effect has already been separately
    recorded. Case has been called out several times since morning but the accused
    inspite of lapse of more than 300 days from the date of publication of above said
    proclamation has failed to appear before this court. Even the necessary
    compliance of section 83 of Cr.P.C has been made as complainant/id. Counsel for
    complainant has suffered a statement to the effect thathatt he could not lay hand on
    the property of accused despite making best efforts. Therefore, in view of the
    failure on the part of accused to appear in the court inspite of lapse of more than
    30 days from the date of publication of above said proclamation ac accused
    cused is
    MAHAVIR SINGH hereby declared as proclaimed person. The evidence of the complainant under
    2026.08.07 15:12
    I attest to the accuracy and
    authenticity of this order/ judgment
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    Section 299Cr.P.C. is hereby closed by court order. Intimation in this regard be
    sent to P.O. Staff, office of SSP Karnal. A copy of this order be given dasti to the
    Naib Court/parocar for forwarding of the same to the SHO concerned after
    proper receipt to register an FIR against the accused u/s 174A of IPC and send
    the copy of FIR to this court within a period of three days. File be consigned to
    record-room with direction to put a badge on it so that the same can be placed
    before the court on arrest or surrender of the accused.”

    3. Learned counsel for the petitioner has submitted that the impugned

    FIR, has its genesis, in a criminal complaint filed against the petitioner (herein) under

    Section 138 of the NI Act, in proceedings whereof the petitioner was declared as a

    proclaimed person & hence the impugned FIR came to be registered against the

    petitioner. Learned counsel for the petitioner has argued that the petitioner could not

    appear in the complaint case as the petitioner was having business in Raigarh,

    Chhatisgarh and had travelled outside the State to search better business opportunity,

    thus, the petitioner had no prior information regarding the complaint in question and

    had also not been served with any notice. Learned counsel has further submitted that

    thereafter, the petitioner was declared as proclaimed person. Learned counsel has also

    submitted that upon gaining the knowledge about pendency of complaint in question,

    he appeared before the concerned trial Court and was admitted to bail. Thereafter, the

    petitioner paid all the claim/ money to the complainant – Bank and nothing remains

    due. Learned counsel has further submitted that on 11.06.2025, counsel for the

    complainant – Bank suffered a statement in the complaint case before the trial Court

    and pursuant to which, vide order dated 11.06.2025 (Annexure P-3), the complaint in

    question was dismissed as withdrawn by the learned trial Court.

    3.1. It has been further iterated that since the criminal complaint under

    Section 138 of NI Act, has already been withdrawn as the rival parties had entered

    into a compromise, therefore, no useful purpose would be served by continuation of

    the proceedings qua the impugned FIR. To buttress this aspect of his argument,

    learned counsel for the petitioner has relied upon the order dated 11.06.2025

    (Annexure P-3) passed by the JMIC, Karnal, which reads thus:

    “File taken up today as an application to withdraw the complaint.
    Complainant appeared and suffered a statement that compromise has been
    effected between parties and as per the instructions of the complainant he does
    not want to proceed with the present complaint and withdraw the same. Heard.

    MAHAVIR SINGH
    2026.08.07 15:12
    I attest to the accuracy and

    authenticity of this order/ judgment
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    3

    Keeping in view the above statement, present complaint is hereby dismissed as
    withdrawn. File be consigned to record room after due compliance.”

    On the strength of above arguments, learned counsel for the petitioner

    has pressed for grant of petition in hand.

    4. Learned State counsel has filed reply by way of an affidavit dated

    04.04.2026, in Court today, which is taken on record. Raising submissions in tandem

    with the said reply, learned State counsel has opposed the petition in hand. He,

    however, does not dispute the fact that the parties have amicably resolved the matter

    and the main complaint stands dismissed as withdrawn.

    5. I have heard learned counsel for the rival parties and have perused the

    paper-book.

    6. The seminal question that arises for consideration in the present

    petition is as to whether the impugned FIR (as also proceedings arising therefrom)

    under Section 209 of BNS (erstwhile Section 174-A of the IPC) deserves to be

    quashed in the factual matrix of the present case.

    7. At this juncture; it would be apposite to refer herein to a judgment of

    this Court passed in CRM-

    CRM-M-51049-
    51049-2019 titled as Mohammad Hanif Attari
    Attari vs. State

    of Haryana, decided on 06.07.2023;

    06.07.2023 relevant whereof reads as under:

    “3. In view the fact that after the principle proceedings in which the petitioner was declared
    Proclaimed Offender stand concluded, the question would arise is: ‘whether in the given
    circumstances, proceedings under Section 174A of the IPC pursuant to FIR No.425 dated
    17th of November, 2017 can be allowed to continue.

    4. The question framed ibid is no more res integra and already stands answered by Co-
    ordinate Bench of this Court in CRM-M-43813-2018 titled as “Baldev Chand Bansal v. State
    of Haryana and another
    ” vide order dated 29.01.2019, which held as under:

    “Prayer in this petition is for quashing of FIR No.64 dated 15.02.2017 filed
    under Section 174A of the Indian Penal Code registered at Police Station Sector-
    5, Panchkula and all other subsequent proceedings arising thereof as well as
    order dated 24.10.2016 passed by the trial Court vide which a direction was
    issued to register the aforesaid FIR.”

    XX XXX XXXX
    Learned counsel for the petitioner has relied upon the decisions rendered by this
    Court in “Vikas Sharma v. Gurpreet Singh Kohli and another (supra), 2017, (3)
    L.A.R.584, Microqual Techno Limited and others v. State of Haryana and
    another, 2015 (32) RCR (Criminal) 790 and “Rajneesh Khanna v. State of
    Haryana and another” 2017 (3) L.A.R. 555 wherein in an identical circumstance,
    this Court has held that since the main petition filed under Section 138 of the
    Act stands withdrawn in view of an amicable settlement between the parties,
    therefore, continuation of proceedings under Section 174A of IPC shall be
    nothing but an abuse of the process of law.

    XX XXX XXXX
    In view of the same, I find merit in the present petition and accordingly, present
    petition is allowed and the impugned order dated 24.10.2016 passed by Judicial
    Magistrate, 1st Class, Panchkula as well as FIR No.64 dated 15.02.2017
    registered under Section 174A of the Indian Penal Code at Police Station Sector-

    MAHAVIR SINGH
    2026.08.07 15:12
    I attest to the accuracy and

    authenticity of this order/ judgment
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    5, Panchkula and all other subsequent proceedings arising thereof, are hereby
    quashed.”

    5. Same is the view of another Co-ordinate Bench in the “Ashok Madaan v. State of
    Haryana and another
    ” reported as 2020 (4) RCR (Criminal) 87, wherein it has been held that:

    “No doubt, the learned counsel for the respondent has vehemently argued that
    the offence under Section 174A I.P.C. is independent of the main case,
    therefore, merely because the main case has been dismissed for want of
    prosecution, the present petition cannot be allowed, however, keeping in view
    the fact that the present FIR was registered only on account of absence from the
    proceedings in the main case which had been subsequently regularised by the
    court while granting bail to the petitioner, the default stood condoned. In such
    circumstances, continuation of proceedings under Section 174A LP.C. shall be
    abuse of the process of court.

    7. Accordingly, the petition is allowed. FIR No. 446 dated 21.08.2017,
    registered under Section 174A I.PC. at Police Station Kotwali, District
    Faridabad, as well as consequential proceedings shall stand quashed.”

    7.1. More recently, the Hon’ble Supreme Court in a judgment titled as

    Daljit Singh vs. State of Haryana and Another,
    Another Criminal Appeal No.4359 of 2024

    decided on 02.01.2025; has held that:

    “7.3 Now, what happens if the status under Section 82 Cr.P.C. is nullified i.e.,
    the person subjected to such proclamation, by virtue of subsequent developments
    is no longer required to be presented before a Court of law. Then, can the
    prosecution still proceed against such a person for having not appeared before a
    Court during the time that the process was in effect. The answer is in the
    affirmative. We say so for the following reasons:-

    (i) The language of Section 174A, IPC says “whoever fails to
    appear at the specified place and the specified time as required by
    proclamation…”. This implies that the very instance at which a person is
    directed to appear, and he does not do so, this Section comes into play;

    (ii) What further flows from the language employed is that the
    instance of non-appearance becomes an infraction of the Section, and
    therefore, prosecution therefor would be independent of Section 82,
    Cr.P.C. being in effect;

    (iii) So, while proceedings under Section 174A IPC cannot be
    initiated independent of Section 82, Cr.P.C., i.e., can only be started post
    the issuance of proclamation, they can continue if the said proclamation
    is no longer in effect.

    (iv) We find that the Delhi High Court has taken this view, i.e.,
    that Section 174A, IPC is a stand-alone offence in Mukesh Bhatia v.State
    (NCT of Delhi) 2022 SCC OnLine Del 1023; Divya Verma v. State 2023
    SCC OnLine Del 2619; Sameena & Anr. v. State GNCT of Delhi & Anr.

    Crl. M.C. No.1470 of 2021, Dated 17th May, 2022 For the reasons afore-
    stated, we agree with the findings made in these judgments/orders. At the
    same time, it stands clarified that we have not commented on the merits
    of the cases.

    (v) Granted that the offence prescribed in Section 174A IPC is indeed
    stand-alone, given that it arises out of an original offence in connection
    with which proceedings under Section 82 Cr.P.C. is initiated and in the
    said offence the accused stands, subsequently, acquitted, it would be
    permissible in law for the Court seized of the trial under such offence, to
    take note of such a development and treat the same as a ground to draw
    the proceedings to a close, should such a prayer be made and the
    circumstances of the case so warrant.

    8. In conclusion, we hold that Section 174A IPC is an independent,
    substantive offence, that can continue even if the proclamation under Section 82,
    Cr.P.C. is extinguished. It is a stand-alone offence. xxxxxxxxx”

    However, the Hon’ble Supreme Court quashed the impugned FIR

    MAHAVIR SINGH (therein) under Section 209 of the BNS (erstwhile Section 174-A of the IPC) since,
    2026.08.07 15:12
    I attest to the accuracy and
    authenticity of this order/ judgment
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    inter alia, the original offence in the form of criminal complaint under Section 138 of

    NI Act, 1881 in the said case had been settled and withdrawn by the rival parties.

    8. It is for the High Court, while exercising its innate plenary powers

    under Section 528 of BNSS, 2023/ 428 of Cr.P.C., 1973, to ratiocinate that it should

    not apply the law in an austere, academic and exacting technical manner, without

    considering its practical implications. The law is not merely a set of programmed,

    nailed-to-the-ground rules, to be applied without context. It must be enforced, while

    bearing in mind, that its purpose is to ensure substantive justice between the parties.

    The statutory provision of Section 174-A of IPC, when perused in the light of ratio

    decidendi of the judgment of the Hon’ble Supreme Court in Daljit Singh‘s case

    (supra), unequivocally shows that an FIR under Section 174-A of the IPC does not

    proprio vigore become liable to be quashed, in case the rival parties have entered into

    a compromise and such criminal complaint/FIR has been compromised and

    quashed/withdrawn accordingly. However, at the same time, the factum of the

    criminal complaint/FIR (in furtherance of proceedings whereof) having been

    compromised/settled, is indubitably, a relevant factor to be considered while dealing

    with a plea for quashing of an FIR (as also proceedings emanating therefrom) under

    Section 174-A of IPC. This fact assumes greater significance considering that the

    initial proceedings pertain exclusively to a private criminal complaint under Section

    138 of NI Act, 1881, which the legislature has expressly classified as a compoundable

    offence. Such litigation, especially in the backdrop of original offence having been

    compromised will have an adverse impact on the overburdened Court-dockets.

    Allowing such prosecution, when initial complaint has been settled/withdrawn would

    undermine the legislative intent and distort the remedial nature of Section 138 of NI

    Act of 1881. It would tantamount to contravening the principles of fairness,

    proportionality, and justice in criminal proceedings. A literal interpretation may

    sometimes lead to unjust outcomes that also contradict the law’s underlined purpose.

    Therefore, the High Court under its inherent jurisdiction must balance the letter of law

    with its spirit, ensuring fair and equitable results. This approach underscores law’s
    MAHAVIR SINGH
    2026.08.07 15:12
    I attest to the accuracy and
    authenticity of this order/ judgment
    CRM-

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    6

    role as an apparatus for fostering societal harmony and addressing the real-world

    complexities, efficaciously as also effectively, rather than mere literal/technical

    compliance.

    9. The inherent jurisdiction under Section 528 BNSS, 2023/ Section 482

    Cr.P.C., 1973 is primarily aimed at preventing abuse of judicial process and securing

    the ends of justice. Thus, when the dispute is essentially personal in nature and a

    genuine compromise has been reached, the High Court may intervene to quash the

    criminal proceedings, recognizing the continuation thereof would be non-productive

    and unjust in the given circumstances. The inherent powers of a High Court are

    powers which are incidental replete powers, which if did not so exist, the Court would

    be obliged to sit still and helplessly see the process of law and Courts being abused

    for the purposes of injustice. In other words; such power(s) is intrinsic to a High

    Court, it is its very life-blood, its very essence, its immanent attribute. Without such

    power(s), a High Court would have form but lack the substance. These powers of a

    High Court hence deserve to be construed with the widest possible amplitude. These

    inherent powers are in consonance with the nature of a High Court which ought to be,

    and has in fact been, invested with power(s) to maintain its authority to prevent the

    process of law/Courts being obstructed or abused. It is a trite posits of jurisprudence

    that though laws attempt to deal with all cases that may arise, the infinite variety of

    circumstances which shape events and the imperfections of language make it

    impossible to lay down provisions capable of governing every case, which in fact

    arises. A High Court which exists for the furtherance of justice in an indefatigable

    manner, should therefore, have unfettered power(s) to deal with situations which,

    though not expressly provided for by the law, need to be dealt with, to prevent

    injustice or the abuse of the process of law and Courts. The juridical basis of these

    plenary power(s) is the authority, in fact the seminal duty and responsibility of a High

    Court, to uphold, to protect and to fulfill the judicial function of administering justice,

    in accordance with law, in a regular, orderly and effective manner. In other words;

    Section 528 of BNSS, 2023 reflects peerless powers, which a High Court may draw
    MAHAVIR SINGH
    2026.08.07 15:12
    I attest to the accuracy and
    authenticity of this order/ judgment
    CRM-

    CRM-M-54474-
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    7

    upon as necessary whenever it is just and equitable to do so, in particular to ensure the

    observance of the due process of law, to prevent vexation or oppression, to do justice

    nay substantial justice between the parties and to secure the ends of justice.

    10. Keeping in view the entirety of the attending facts and circumstances of

    the case in hand; especially the original offence being an offence under Section 138 of

    Negotiable Instruments Act of 1881, the original offence alleged to have been

    committed in the year 2018, the subject matter of the original offence having been

    settled amicably between the parties and the criminal complaint under Section 138 of

    the NI Act having been withdrawn on the basis of such settlement/compromise; this

    Court deems it appropriate that the impugned FIR as also all proceedings emanating

    therefrom deserve to be quashed.

    11. It is, hence, directed as under:

                         (i)               Instant petition is allowed;
                                                               allowed
    
                         (ii)              The FIR No.789 dated 10.12.2021, under Section 174-A of IPC,
    
    

    registered at Police Station Karnal Civil Line, District Karnal (Aannexure P-1), stands

    quashed qua the petitioner;

    (iii) All pending application(s), if any, stands disposed of.

    (SUMEET GOEL)
    JUDGE
    August 07,
    07, 2026
    mahavir

    Whether speaking/reasoned: Yes/No

    Whether reportable: Yes/No

    MAHAVIR SINGH
    2026.08.07 15:12
    I attest to the accuracy and
    authenticity of this order/ judgment



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