Delhi High Court – Orders
Vishal Yadav & Ors vs State Nct Of Delhi & Anr on 20 April, 2026
Author: Prateek Jalan
Bench: Prateek Jalan
$~21-Q
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CRL.M.C. 7024/2025
VISHAL YADAV & ORS. .....Petitioner
Through: Mr. Vipul Lamba, Adv.
Versus
STATE NCT OF DELHI & ANR. .....Respondent
Through: Mr. Hitesh Vali, APP
CORAM:
HON'BLE MR. JUSTICE PRATEEK JALAN
ORDER
% 20.04.2026
CRL.M.A. 12203/2026 (for condonation of delay in filing amended
memo of parties)
1. This application has been filed by the petitioner seeking
condonation of 138 days’ delay in filing the amended memo of parties.
2. For the reasons stated, the application is allowed, and the delay of
138 days in filing the amended memo of parties is condoned.
3. The application stands disposed of.
CRL.M.C. 7024/2025
4. The petitioners have preferred the present petition seeking
quashing of FIR No. 381/2014, dated 08.09.2014, registered at Police
Station South Campus, South District, Delhi, for offences punishable
under Sections 323/341/506/34 of the Indian Penal Code, 1860 [“IPC“],
alongwith all consequential proceedings arising therefrom, on the basis of
CRL.M.C. 7024/2025 Page 1 of 7
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a settlement between the parties.
5. Pursuant to order dated 30.10.2025, the petitioner has filed an
amended memo of parties impleading respondent No. 3, who was also
injured in the incident pertaining to the impugned FIR.
6. Issue notice. Mr. Hitesh Vali, learned Additional Public
Prosecutor, accepts notice on behalf of the State. Learned counsel accepts
notice on behalf of respondent Nos. 2 and 3.
7. The petitioners are present before the Court and have been duly
identified by the Investigating Officer [“IO”] as well as by their learned
counsel. Respondent No. 2 is also present in Court, and respondent No. 3
is present through video conference. They have also been identified by
the IO as well as by their learned counsel.
8. The petitioners and respondent No. 2 were in the same college at
ARSD College, Delhi University. The FIR came to be registered at the
instance of respondent No. 2, who alleged that on 08.09.2014 at around
11:40 AM, upon entering the college premises, he saw respondent No. 3
involved in a fight. When he approached, the petitioners, alongwith Rahul
Hans and Anshu Kumar instigated violence by calling others to beat him.
As respondent Nos 2 and 3 attempted to flee, their way was blocked, and
they were assaulted and beaten with kicks and punches, while petitioner
No. 2 assaulted respondent No. 2 with a stick.
9. I am informed that the injuries sustained were simple in nature and
that no sharp weapon or firearm was used in the commission of the
alleged offence. Respondent Nos. 2 and 3, who are present, state that
there were no lasting consequences.
10. During the pendency of the present proceedings, the parties have
CRL.M.C. 7024/2025 Page 2 of 7
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amicably resolved their disputes by way of a Settlement Deed executed
between them on 13.08.2025.
11. The parties have confirmed before this Court that they have settled
their disputes amicably. Respondent Nos. 2 and 3 also confirm that they
do not wish to pursue the criminal proceedings against the petitioners.
12. Mr. Vipul Lamba, learned counsel for the petitioner, submits that
proceedings arising out of the impugned FIR qua Rahul Hans and Anshu
Kumar have already been quashed by this Court vide orders dated
06.07.2023 in CRL.M.C. 3521/2023 and 08.08.2023 in CRL.M.C.
5600/2023 respectively.
13. Even in cases involving non-compoundable offences, the Supreme
Court has consistently held that, in appropriate cases, the High Court may
exercise its inherent jurisdiction to quash an FIR and the proceedings
arising therefrom on the basis of a settlement between the parties. In Gian
Singh v. State of Punjab and Anr.1, the Supreme Court 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 the1
(2012) 10 SCC 303.
CRL.M.C. 7024/2025 Page 3 of 7
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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 & 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
petition for quashing the criminal proceedings is filed, the guiding2
Emphasis supplied.
3
(2014) 6 SCC 466.
CRL.M.C. 7024/2025 Page 4 of 7
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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. The present case stems from a dispute between students of the
same college, which culminated in a scuffle. More than twelve years have
passed since the incident. During the pendency of the proceedings, the
parties have resolved their disputes amicably by way of a settlement, and
the injuries sustained by respondent Nos. 2 and 3 are stated to be simple
in nature, and there are no lasting consequences. In view of these
circumstances, I am of the view that the present case warrants the
exercise of its inherent jurisdiction, as such an order would advance the
4
Emphasis supplied.
CRL.M.C. 7024/2025 Page 5 of 7
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ends of justice by enabling the parties to live in peace and harmony rather
than perpetuating animosity.
15. Applying the principles enunciated by the Supreme Court, it is
further noted that respondent Nos. 2 and 3 have categorically affirmed
before this Court that the settlement has been arrived at voluntarily. In the
given factual matrix, the continuation of the criminal proceedings is
unlikely to culminate in a conviction and would amount to an empty
formality, thereby unnecessarily burdening the judicial system and
leading to the avoidable consumption of public resources.
16. Proceedings against two other co-accused, being Rahul Hans and
Anshu Kumar, have already been quashed on the basis of settlement by
this Court. There is therefore no impediment in grating the relief sought.
17. The petition is, accordingly, allowed, FIR No. 381/2014, dated
08.09.2014, registered at Police Station South Campus, South District,
Delhi, for offences punishable under Sections 323/341/506/34 of IPC,
alongwith all consequential proceedings arising therefrom, is hereby
quashed.
18. Having regard to the circumstances giving rise to the impugned
FIR and the nature of allegations therein, I accept the suggestion of Mr.
Vali that the present case warrants the imposition of community service
upon the petitioners. The petitioners are accordingly directed to report to
the Medical Superintendent, VMMC & Safdarjung Hospital on
24.04.2026 at 11:00 AM., who shall assign them suitable duties and tasks
for 3 hours a day for 6 sessions, to be completed within the next two
months. The nature, and timing of such duties shall be determined by the
Medical Superintendent, and may be assigned to each of the petitioners
CRL.M.C. 7024/2025 Page 6 of 7
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separately or together. The petitioners shall file compliance affidavits
alongwith a certificate issued by the said hospital within one week
thereafter.
19. The parties shall remain bound by the terms of the settlement.
20. The petition, alongwith the pending applications, is accordingly
disposed of.
PRATEEK JALAN, J
APRIL 20, 2026
Tg/AD/
CRL.M.C. 7024/2025 Page 7 of 7
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