Allowed¶54

Deepak Arora & Ors. v. the State (Nct of Delhi) & Ors.

Delhi HC13 Jul 2026W.P.(CRL)/2007/2026

Case brief

AI extract

What is this about?

Delhi High Court; quashing of FIR on settlement; W.P.(CRL) 2007/2026; Deepak Arora & Ors.; FIR No. 106/2026 dated 26.02.2026; Sections 420/506/34 IPC; P.S. Shahbad Dairy; District Outer North; Rohini Sector-29 plots B-3/698-699, B-2/49, B-2/50; Settlement Deed 09.07.2026; Rs. 3.52 crores; Article 226 Constitution; inherent powers; non-compoundable offences; predominantly civil flavour; Gian Singh (2012) 10 SCC 303; Narinder Singh (2014) 6 SCC 466; Prateek Jalan, J.; 13.07.2026; petition allowed; consequential proceedings quashed.

What did the court decide?

Petition allowed: FIR No. 106/2026 dated 26.02.2026, registered under Sections 420/506/34 of the IPC, and all consequential proceedings arising therefrom quashed; parties to remain bound by the terms of the settlement; pending application disposed of with the petition. ¶54

Deepak Arora & Ors. Vs the State (Nct of Delhi) & Ors. — Cheating and Forgery | Delhi HC (2026)

What the court decided

AI extract

Outcome

¶54

Issue for consideration

Whether FIR No. 106/2026 dated 26.02.2026, registered under Sections 420/506/34 IPC at Police Station Shahbad Dairy, and all consequential proceedings emanating therefrom, should be quashed on the ground of settlement between the parties.

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Court's answer

The case arises out of a private property transaction settled between the parties, involving no element of public interest or heinous criminality; it is a fit case in which the inherent powers of the Court may be exercised to quash the FIR.

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Ratio / Principle

Since respondent No. 2 affirmed the voluntary nature of the settlement, further proceedings were unlikely to result in conviction, and continuation of criminal proceedings pursuant to the impugned FIR would be an unnecessary diversion of judicial resources.

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Key takeaways

The settlement property had already been transferred to respondent Nos. 2 and 3, and therefore there was no impediment to the grant of the relief sought.ratio¶47

Detailed headnote1 paragraphs

W.P.(CRL) 2007/2026 & CRL.M.A. 20117/2026 — Deepak Arora & Ors. v. The State (NCT of Delhi) & Ors. — High Court of Delhi at New Delhi — Order of 13.07.2026 — Coram: Prateek Jalan, J. Petitioners, prosecuted via FIR No. 106/2026 dated 26.02.2026 under Sections 420/506/34 IPC at P.S. Shahbad Dairy (District Outer North, Delhi) over 2022–2024 Rohini, Sector-29 property transactions in which respondent No. 2 alleged inducement, retention of Rs. 1.51 crores and non-execution of sale documents despite substantial payments, sought quashing under Article 226 of the Constitution on the ground of settlement. By Settlement Deed dated 09.07.2026 the parties agreed to transfer properties Nos. 49 and 50, Block-B, Pocket-2, Sector-29, Rohini to respondent Nos. 2 and 3 for Rs. 3.52 crores as full and final settlement; counsel confirmed before the Court that the settlement stood implemented and was voluntary. Relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303, and Narinder Singh v. State of Punjab, (2014) 6 SCC 466, the Court held that a private property dispute of predominantly civil character, devoid of public-interest elements or heinous criminality, in which the victim affirmed the settlement's voluntariness and conviction was unlikely, is a fit case for exercise of inherent powers to quash. Held: petition allowed; FIR and all consequential proceedings quashed; parties bound by the settlement terms; pending application disposed of.

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$~95-Q

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- W.P.(CRL) 2007/2026 & CRL.M.A. 20117/2026

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DEEPAK ARORA & ORS. .....Petitioner

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Through: Mr. Pradeep Rana, Advocate.

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versus

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THE STATE (NCT OF DELHI) & ORS. .....Respondent Through: Mr. Amol Sinha, ASC with Mr. Kshitiz Garg, Ms. Chavi Lazarus, Mr. Nitish Dhawan, Advocates. Mr. Sujeet Beniwal, Advocate for R2 and R3.

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CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN

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O R D E R % 13.07.2026

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The petitioners have filed this petition under Article 226 of the Constitution, seeking quashing of FIR No. 106/2026 dated 26.02.2026, registered under Sections 420/506/34 of the Indian Penal Code, 1860, [“IPC”], at Police Station Shahbad Dairy, District Outer North, Delhi, and all consequential proceedings emanating therefrom, on the ground of settlement.

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Issue notice. Mr. Amol Sinha, learned Additional Standing Counsel, accepts notice on behalf of the State. Mr. Sujeet Beniwal, learned counsel, accepts notice on behalf of respondent Nos. 2 – complainant and respondent No. 3.

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W.P.(CRL) 2007/2026

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Page 1 of 6

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This is a digitally signed order.

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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 17/07/2026 at 11:54:37

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The parties are present, and have been identified by their respective learned counsel as well as the Investigating Officer.

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The impugned FIR was registered at the instance of respondent No.2 against the petitioners. The allegations contained therein are that, in the year 2022, respondent No. 2 purchased two plots, bearing Nos. B- 1/292 and B-1/467, Sector-29, Rohini, Delhi, through petitioner Nos. 1 and 2. It is alleged that, thereafter, in 2024, petitioner Nos. 1 and 2 induced him to sell the aforesaid plots and instead purchase the adjoining plots bearing Nos. B-3/698-699, Sector-29, Rohini, Delhi, for a total consideration of Rs. 3.05 crores. Pursuant thereto, respondent No. 2 paid a sum of Rs. 30.50 lakhs to petitioner No. 1 as earnest money. However, he was subsequently informed that the original owner was unwilling to sell the said plots. It is further alleged that respondent No. 2 was thereafter persuaded to purchase plots bearing Nos. B-2/49 and B-2/50 for a total consideration of Rs. 3.52 crores. In connection with the said transaction, respondent No. 2 sold his earlier plots for a consideration of Rs. 2.25 crores, out of which a sum of Rs. 1.51 crores was retained by petitioner Nos. 1 and 2 towards adjustment of the purchase consideration. Additionally, respondent No. 2 paid a sum of Rs. 35 lakhs as earnest money to petitioner No. 3, and a further sum of Rs. 44 lakhs was remitted to the joint owners of Plot No. B-2/50. Despite receipt of the aforesaid amounts and repeated assurances, the sale documents were not executed. 5. The parties have since amicably resolved their disputes, as recorded in a Settlement Deed dated 09.07.2026. The settlement contemplates transfer of the properties bearing Nos. 49 and 50, Block-B, Pocket-2, Sector-29, Rohini, Delhi, to respondent Nos. 2 and 3 for a total

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W.P.(CRL) 2007/2026

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Page 2 of 6

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This is a digitally signed order.

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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 17/07/2026 at 11:54:37

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consideration of Rs. 3.52 crores, towards full and final settlement of all claims.

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Learned counsel for the parties confirm that the settlement has been duly implemented, and was entered into voluntarily, and without any coercion or undue influence.

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

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The Supreme Court has clearly held that, in certain circumstances, the High Courts, in exercise of their extraordinary powers, 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. Reference in this connection can be made to the judgment in Gian Singh v. State of Punjab and Anr.¹ , which held as follows:

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“ 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

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1 (2012) 10 SCC 303.

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W.P.(CRL) 2007/2026

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Page 3 of 6

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This is a digitally signed order.

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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 17/07/2026 at 11:54:37

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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-andfast category can be prescribed. ”²

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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 accepting settlement deeds between parties and quashing the proceedings. The relevant observations in the said decision read as under:

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“ 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.

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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

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2 Emphasis supplied.

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3 (2014) 6 SCC 466.

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W.P.(CRL) 2007/2026

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Page 4 of 6

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This is a digitally signed order.

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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 17/07/2026 at 11:54:37

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either of the aforesaid two objectives .

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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.

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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 .

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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

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The present case arises out of a private property transaction that has since been settled between the parties. The dispute does not involve any element of public interest or heinous criminality. This, in my view, is a fit case in which the inherent powers of this Court may be exercised to quash the FIR in question. As respondent No. 2 has affirmed the voluntary nature of the settlement, it is also unlikely that further proceedings would result in conviction. Continuation of criminal proceedings pursuant to the impugned FIR would, therefore, be an unnecessary diversion of judicial resources.

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As noted above, the property has already been transferred to respondent Nos. 2 and 3. There is, therefore, no impediment to the grant of the relief sought.

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Having regard to the above discussion, the petition is allowed, and

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4 Emphasis supplied.

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W.P.(CRL) 2007/2026

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Page 5 of 6

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This is a digitally signed order.

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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 17/07/2026 at 11:54:37

¶54

FIR No. 106/2026 dated 26.02.2026, registered under Sections 420/506/34 of the IPC, alongwith all consequential proceedings arising therefrom, is hereby quashed.

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

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The petition, alongwith pending application, stands disposed of in terms of the above.

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PRATEEK JALAN, J

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JULY 13, 2026 tg/KA/

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W.P.(CRL) 2007/2026

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Page 6 of 6

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This is a digitally signed order.

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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 17/07/2026 at 11:54:37

Deepak Arora & Ors. v. the State (Nct of Delhi) & Ors.

Case brief

What is this about?

What did the court decide?

Deepak Arora & Ors. v. the State (Nct of Delhi) & Ors.

Case brief

What is this about?

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What the court decided

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