Mr. Naseem Ahmad & Ors vs The State Of Nct Of Delhi & Anr on 2 April, 2026

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    Mr. Naseem Ahmad & Ors vs The State Of Nct Of Delhi & Anr on 2 April, 2026

    Author: Prateek Jalan

    Bench: Prateek Jalan

                              $~81
                              *         IN THE HIGH COURT OF DELHI AT NEW DELHI
                              +         CRL.M.C. 2434/2026, CRL.M.A. 9935/2026
                                        MR. NASEEM AHMAD & ORS.                  .....Petitioner
                                                     Through: Mr. Arun Kumar Sharma, Mr.
                                                              Vaibhav Sharma, Mr. Nikhil
                                                              Vashishth, and Mr. Sagar Mitra,
                                                              Advocates
    
                                                                      versus
    
                                  THE STATE OF NCT OF DELHI & ANR.             .....Respondent
                                                Through: Mr. Hitesh Vali, APP for State
                                                           with SI Kajal Rani, PS Seemapuri
                                                           Mr. Rajesh Kumar, Advocate for
                                                           R2
                              CORAM:
                              HON'BLE MR. JUSTICE PRATEEK JALAN
                                                ORDER
    

    % 02.04.2026

    1. The petitioners have filed this 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. 385/2023, dated 24.05.2023, registered at
    Police Station Seemapuri, under Sections 498A/406/34 of the Indian
    Penal Code, 1860 [“IPC“], and Section 4 of the Dowry Prohibition Act,
    1961 [“DP Act“], and all proceedings emanating therefrom, on the
    ground of settlement.

    SPONSORED

    2. Issue notice. Mr. Hitesh Vali, learned Additional Public
    Prosecutor, accepts notice on behalf of the State. Mr. Rajesh Kumar,
    learned counsel, accepts notice on behalf of respondent No.2.

    CRL.M.C. 2434/2026 Page 1 of 6

    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 06/04/2026 at 21:12:06

    3. The petitioner Nos. 1 and 4 are present by video conference, while
    rest of the petitioners are present in Court, and are identified by their
    learned counsel, as well as by the Investigating Officer [“IO”].
    Respondent No. 2 is also present in person, and is identified by her
    learned counsel and the IO.

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

    5. The impugned FIR is registered at the instance of respondent No.2,
    who was the wife of petitioner No. 1. Petitioner No. 2 is the mother of
    petitioner No.1. Petitioner No. 3 is the sister of petitioner No. 1.
    Petitioner No. 4 is the brother-in-law of petitioner No. 1, and petitioner
    Nos. 5 and 6 are the brothers of petitioner No. 1.

    6. The petitioner No. 1 and respondent No. 2 were married on
    25.07.2016. Due to matrimonial discord and temperamental differences
    between the parties, they have been living separately since 10.06.2022.
    No child was born from the wedlock.

    7. Respondent No.2 lodged a formal complaint before the Crime
    against Women Cell, and the same culminated into the impugned FIR,
    against six accused persons, being her husband, mother-in-law, sister-in-
    law, and three brothers-in-law.

    8. During the pendency of proceedings, the parties have entered into a
    settlement, recorded in a Settlement Deed dated 09.11.2025.

    9. The settlement contemplates that the parties have reconciled their
    disputes and resumed cohabitation as husband and wife. Respondent No.
    2, who is personally present before this Court, states that she has fully
    reconciled with petitioner No. 1 and that no disputes or grievances now

    CRL.M.C. 2434/2026 Page 2 of 6
    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 06/04/2026 at 21:12:06
    subsist between them.

    10. Learned counsel for the parties submit that the settlement was
    arrived at voluntarily, without any coercion, undue influence, or pressure
    from any side.

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

    12. Although the offence under Section 498A of IPC and Section 4 of
    DP Act are non-compoundable, the Supreme Court has clearly held that,
    in certain circumstances, the High Courts, in exercise of their powers
    under Section 528 of BNSS (corresponding to Section 482 of CrPC), can
    quash criminal proceedings, even with respect to non-compoundable
    offences, on the ground that there is a compromise between the accused
    and the complainant, especially when no overarching public interest is
    adversely affected.

    13. The Supreme Court, in Gian Singh v. State of Punjab & Anr.1 has
    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

    1
    (2012) 10 SCC 303.

    CRL.M.C. 2434/2026 Page 3 of 6

    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 06/04/2026 at 21:12:06
    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-fast category can be
    prescribed.”2

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

    2
    Emphasis supplied.

    3

    (2014) 6 SCC 466.

    CRL.M.C. 2434/2026 Page 4 of 6

    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 06/04/2026 at 21:12:06
    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 him by not
    quashing the criminal cases.”4

    14. In the present case, the dispute stems from a matrimonial
    relationship that has since been amicably resolved. Petitioner No. 1 and
    respondent No. 2 have reconciled and are living together for the last four
    months, and in such circumstances, the continuation of the criminal
    proceedings would be prejudicial to their marital harmony. Applying the
    principles laid down by the Supreme Court, respondent No. 2 has
    unequivocally stated before this Court that the settlement was entered into
    voluntarily, without any coercion or undue influence. In these

    CRL.M.C. 2434/2026 Page 5 of 6
    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 06/04/2026 at 21:12:06
    circumstances, the continuation of the criminal proceedings is unlikely to
    lead to a conviction and would merely serve as a procedural formality,
    thereby imposing an unnecessary burden on the justice system and
    diverting valuable judicial resources without serving any meaningful
    purpose.

    15. Having regard to the above discussion, the petition is allowed, and
    FIR No. 385/2023, dated 24.05.2023, registered at Police Station
    Seemapuri, under Section 498A/406/34 of IPC, alongwith all
    consequential proceedings arising therefrom, is hereby quashed.

    16. The parties will remain bound by the terms of the settlement.

    17. The petition accordingly stands disposed of.

    PRATEEK JALAN, J
    APRIL 2, 2026
    ‘SV’/AD/

    4
    Emphasis supplied.

    CRL.M.C. 2434/2026 Page 6 of 6

    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 06/04/2026 at 21:12:06



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