Delhi High Court – Orders
Zile Singh vs State Of Nct Of Delhi & Anr on 21 April, 2026
Author: Prateek Jalan
Bench: Prateek Jalan
$~29 to 31-Q
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CRL.M.C. 9228/2025, CRL.M.A. 38517-38518/2025
ZILE SINGH .....Petitioner
Through: Mr. Aditya Singh, Advocate.
versus
STATE OF NCT OF DELHI & ANR. .....Respondent
Through: Mr. Hitesh Vali, APP with SI
Vinod Kumar, PS Mehrauli.
Mr. Faiyaz Hasan, Mr. Nadeem
Khan and Mr. Neerav Anand,
Advocates for R2.
+ CRL.M.C. 1753/2026, CRL.M.A. 7151-7152/2026
BHARAT MEHLAWAT AND ORS. .....Petitioner
Through: Mr. Faiyaz Hasan, Mr. Nadeem
Khan and Mr. Neerav Anand,
Advocates.
versus
STATE NCT OF DELHI AND ORS .....Respondent
Through: Mr. Hitesh Vali, APP with SI
Vinod Kumar, PS Mehrauli.
Mr. Aditya Singh, Advocate for R2
and R3.
+ CRL.M.C. 1765/2026, CRL.M.A. 7203-7204/2026
NUTAN PANWAR & ORS. .....Petitioner
Through: Mr. Faiyaz Hasan, Mr. Nadeem
Khan and Mr. Neerav Anand,
Advocates.
versus
CRL.M.C. 9228/2025 & Connected Matters Page 1 of 7
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STATE OF DELHI & ANR. .....Respondent
Through: Mr. Hitesh Vali, APP with SI
Vinod Kumar, PS Mehrauli.
Mr. Aditya Singh, Advocate for
R2.
CORAM:
HON'BLE MR. JUSTICE PRATEEK JALAN
ORDER
% 21.04.2026
1. The present petitions have been filed 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 three cross-FIRs, being – [a] FIR No. 319/2017 dated
23.05.2017, registered under Sections 323/354/354B/506/509/34 of the
Indian Penal Code, 1860 [“IPC“] [subject matter of CRL.M.C.
9228/2025]; [b] FIR No. 210/2017 dated 07.04.2017, registered under
Sections 356/323/506/509/34 of the IPC [subject matter of CRL.M.C.
1753/2026]; and [c] FIR No. 324/2017 dated 25.05.2017, registered under
Sections 323/341/354/506/34 of the IPC [subject matter of CRL.M.C.
1765/2026]. The aforesaid FIRs were registered at Police Station
Mehrauli, District South, New Delhi. The petitions are founded on a
compromise arrived at between the parties.
2. Issue notice. Mr. Hitesh Vali, learned Additional Public
Prosecutor, accepts notice on behalf of the State in all the petitions. Mr.
Faiyaz Hasan, learned counsel, accepts notice on behalf of respondent
No. 2 in CRL.M.C. 9228/2025. Mr. Aditya Singh, learned counsel,
accepts notice of behalf of respondent Nos. 2 and 3 in CRL.M.C.
CRL.M.C. 9228/2025 & Connected Matters Page 2 of 7
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1753/2026, and respondent No. 2 in CRL.M.C. 1765/2026.
3. The petitions are taken up for disposal with the consent of learned
counsel for the parties.
4. The disputes between the parties, who are family members, stem
from a property dispute and led to the registration of cross-FIRs at the
instance of respondent No. 2 in the respective petitions. Upon completion
of the investigation, chargesheets have been filed in all three cases.
5. The parties seek quashing of the FIRs on the ground that they have
now decided to bury the hatchet. To this end, the parties have entered into
settlements dated 20.03.2025 and 03.05.2025, under the aegis of the
Mediation Centre, Saket Courts, New Delhi.
6. In view of the aforesaid, the parties seek quashing of the impugned
FIRs.
7. The parties are present in Court and have been duly identified by
the Investigating Officer, as well as by their respective learned counsel.
8. The settlements do not involve any monetary consideration, and
record that the parties do not wish to pursue criminal proceedings against
each other. Affidavits of the respective complainants, signifying their no-
objection to the quashing of the impugned FIRs and all consequential
proceedings arising therefrom, have also been placed on record.
9. The parties have confirmed before the Court that they have
amicably settled their disputes, and state that the settlements have been
implemented in full. The complainants in all the three petitions, who are
present in Court and represented by counsel, state that the allegations
under Sections 354 and 354B of the IPC arose out of a misunderstanding,
and that they do not wish to pursue the same.
CRL.M.C. 9228/2025 & Connected Matters Page 3 of 7
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10. I am also informed that a petition [CRL.M.C. 7616/2025: Sunil
Kumar and Ors. v. State (NCT of Delhi) and Anr.], seeking quashing of a
connected FIR bearing No. 211/2017 registered at Police Station
Mehrauli, District South, New Delhi, under Sections
356/354/342/506/509/34 of the IPC, has been allowed by this Court vide
order dated 22.12.2025.
11. Although the offences under Sections 354, 354B, and 356 of the
IPC are non-compoundable, the Supreme Court has clearly held that, in
certain circumstances, the High Courts, in exercise of their powers under
Section 482 of the CrPC [corresponding to Section 528 of the BNSS], 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
12. In Gian Singh v. State of Punjab and Anr. [(2012) 10 SCC 303],
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 the
offences committed by public servants while working in that capacity,CRL.M.C. 9228/2025 & Connected Matters Page 4 of 7
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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.”
[Emphasis supplied.]
Further, in Narinder Singh and Ors. v. State of Punjab and Anr. [(2014) 6
SCC 466], 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 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
CRL.M.C. 9228/2025 & Connected Matters Page 5 of 7
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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.”
[Emphasis supplied.]
13. In the present case, the impugned FIRs arise out of a property
dispute amongst family members. The complainants in CRL.M.C.
9228/2025 and CRL.M.C. 1765/2026 have stated that the allegations
under Sections 354/354B of the IPC arose on account of
misunderstandings, and that they do not wish to pursue the same. The
allegations, therefore, do not implicate any larger public interest or
involve grave criminality. The parties have also agreed to bury the
hatchet.
14. Applying the principles laid down by the Supreme Court, it is
pertinent to note that the complainants have also affirmed the voluntary
nature of the settlement before the Court. In these circumstances, the
continuation of criminal proceedings is unlikely to result in a conviction
and would serve no useful purpose, while merely adding to the burden on
the justice system and causing unnecessary consumption of public
CRL.M.C. 9228/2025 & Connected Matters Page 6 of 7
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resources.
15. The petitions are, therefore, allowed, and all proceedings
emanating from FIR No. 319/2017 dated 23.05.2017, registered under
Sections 323/354/354B/506/509/34 of the IPC; FIR No. 210/2017 dated
07.04.2017, registered under Sections 356/323/506/509/34 of the IPC;
and FIR No. 324/2017 dated 25.05.2017, registered under Sections
323/341/354/506/34 of the IPC, all registered at Police Station Mehrauli,
District South, New Delhi, are hereby quashed.
16. However, considering that the criminal justice machinery had been
set in motion and that considerable time of both the State and the Court
has been expended, the petitioners in each of the three cases will
collectively deposit costs of Rs. 25,000/- to Delhi High Court Bar
Association [A/C No. 15530110179338, IFSC No. UCBA0001553, Bank
Name: UCO Bank, Branch: Delhi High Court], within two weeks from
today. An affidavit of compliance shall be filed within two weeks
thereafter.
17. The petitions, alongwith pending applications, accordingly stand
disposed of.
PRATEEK JALAN, J
APRIL 21, 2026
‘pv/KA’/
CRL.M.C. 9228/2025 & Connected Matters Page 7 of 7
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