Shri Harpreet Singh & Ors. Vs the State (Govt of NCT of Delhi) & Anr.

$~65 Q

* IN THE HIGH COURT OF DELHI AT NEW DELHI

- CRL.M.C. 2028/2026

SHRI HARPREET SINGH & ORS. .....Petitioners Through: Mr. Avinash Chandra Vats, Mr. Kshitij K. Jha, Advocates, Advocates along with Petitioners in person.

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versus

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THE STATE (GOVT OF NCT OF DELHI) & ANR. .....Respondents Through: Mr. Yudhvir Singh Chauhan, APP. SI Chetan Panwar, PS-Chhawla. Complainant in person with two other victims.

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CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN

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O R D E R % 17.07.2026

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The petitioners have filed the present 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 the quashing of FIR No. 370/2025, dated 17.09.2025, registered at Police Station Chhawala, District Dwarka, Delhi, under Sections 115(2)/126(2)/3(5) of the Bharatiya Nyaya Sanhita, 2023, [“BNS”], together with all proceedings arising therefrom, on the ground that the dispute between the parties has been amicably settled.

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CRL.M.C. 2028/2026

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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 20/07/2026 at 11:17:44

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The petition is taken up for disposal with the consent of learned counsel for the petitioners, and the respondent No. 2.

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At the outset, it is noted that, by order dated 19.03.2026, the learned Additional Public Prosecutor submitted that two other victims, namely, Sambhav and Vishal, had not been impleaded as parties to the present petition. Accordingly, an application has been filed vide Diary No. 279637/2026 seeking their impleadment, alongwith their respective affidavits. Since Sambhav is a minor, the application has been filed on his behalf through his father, who is also the complainant in the present case. A fresh Settlement Deed dated 29.06.2026, executed between the petitioners, respondent No. 2 and the aforesaid victims, has also been handed over in Court alongwith the application and affidavits. The said documents are taken on record. The application is allowed, and the other victims are impleaded as respondent Nos. 3 and 4. The Registry is directed to assign the application a number.

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The petitioners are present in Court and are identified by their learned counsel as well as by the Investigating Officer. Respondent No. 2/complainant is also present in person, along with respondent Nos. 3 and 4, who are duly identified by the Investigating Officer. Since respondent No. 4 is a minor, he is represented through his father, i.e. respondent No. 2. Respondent Nos. 2 to 4 state that they do not wish to avail the assistance of legal counsel.

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Petitioner No. 5 is stated to be the Director of Ujjwal Bhavishya Nasha Mukti Sansthan, where respondent No. 2 had been employed in a managerial capacity for approximately ten months. Respondent No. 2 is stated to have left the institute about a month prior to the incident on

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CRL.M.C. 2028/2026

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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 20/07/2026 at 11:17:44

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account of an alleged non-payment of his salary.

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As per the Status Report, the prosecution case is that, on 16.09.2025, respondent No. 2, accompanied by his brother-in-law, respondent No. 3, and his son, respondent No. 4, was intercepted by petitioner No. 5 alongwith petitioner Nos. 1 to 4, whereupon they were allegedly assaulted. It is alleged that petitioner No. 5 assaulted respondent No. 2 with a baseball bat, while petitioner Nos. 1 and 3 restrained him. Petitioner No. 2 is alleged to have pelted bricks during the incident, causing injuries to respondent No. 3, and petitioner No. 3 is further alleged to have assaulted respondent No. 4. Petitioner No. 4 is stated to have remained present at the spot and recorded the incident on his mobile phone. The Status Report further states that respondent No. 2 sustained injuries which were subsequently opined to be grievous, whereas respondent Nos. 3 and 4 also sustained injuries during the incident.

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Although the injuries sustained by the respondent No. 2 were opined to be grievous, on account of a fracture to his hand suffered during the incident, the respondent No. 2 states that he has since fully recovered and did not suffer any permanent or lasting disability. 8. The petitioners and respondent No. 2 had earlier settled their disputes by way of a Settlement Deed dated 07.10.2025. However, pursuant to the impleadment of respondent Nos. 3 and 4 as parties to the present petition, a fresh Settlement Deed dated 29.06.2026 has been executed between the petitioners and respondent Nos. 2 to 4. Under the terms of the said Settlement Deed, the petitioners have agreed to pay the treatment expenses and the cost of repairs of the damaged vehicle towards full and final settlement of all claims arising out of the alleged

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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 20/07/2026 at 11:17:44

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incident, including the salary allegedly due to respondent No. 2 from petitioner No. 5. The Settlement Deed further records that the salary dispute stands fully resolved and that respondent Nos. 3 and 4, whose injuries were minor in nature, have also settled all their claims arising out of the incident.

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Learned counsel for the petitioners, and the respondent Nos. 2 to 4, confirm that the Settlement Deed has been executed voluntarily, without any coercion, undue influence or pressure of any nature.

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

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The Supreme Court has held that, in appropriate circumstances, High Courts, while exercising their powers under Section 528 of the BNSS (corresponding to Section 482 of the CrPC), may quash criminal proceedings, even in cases involving non-compoundable offences, where a compromise has been reached between the accused and the complainant, particularly when no overriding public interest is adversely affected.

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

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1 2012 10 SCC 303.

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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 20/07/2026 at 11:17:44

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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 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

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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:

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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:

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29.1. Power conferred under Section 482 of the Code is to be

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2 Emphasis supplied.

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3 (2014) 6 SCC 466.

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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 20/07/2026 at 11:17:44

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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.

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While exercising the power the High Court is to form an opinion on 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 offences alleged in the present FIR arise out of a personal dispute between the parties, the genesis whereof lies in the employeremployee relationship between petitioner No. 5 and respondent No. 2.

4 Emphasis supplied.

CRL.M.C. 2028/2026

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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 20/07/2026 at 11:17:44

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Although the incident resulted in injuries to respondent Nos. 2 to 4, including a fracture sustained by respondent No. 2, the record indicates that no sharp-edged weapon or firearm was used during the incident. Respondent No. 2 has categorically stated before this Court that he has since fully recovered and has not suffered any permanent or lasting disability. The Settlement Deed further records that the salary dispute, which formed the underlying basis of the discord between the parties, stands fully resolved, and that respondent Nos. 3 and 4 have also amicably settled all their claims arising out of the incident. All the victims are present before this Court and have unequivocally affirmed that the settlement has been arrived at voluntarily, without any coercion, undue influence or pressure of any kind, and have expressed no objection to the quashing of the FIR.

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In these circumstances, the dispute does not involve any overriding public interest or element of such grave criminality as would warrant the continuation of the criminal proceedings despite the settlement. Rather, the possibility of securing a conviction stands substantially diminished in view of the voluntary settlement arrived at between all the affected parties. Consequently, permitting the prosecution to continue would serve no useful purpose and would only result in the unnecessary expenditure of judicial time and public resources.

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Having regard to the above discussion, the petition is allowed, and FIR No. 370/2025, dated 17.09.2025, registered at Police Station Chhawala, District Dwarka, Delhi, under Sections 115(2)/126(2)/3(5) of BNS, alongwith all consequential proceedings arising therefrom, is hereby quashed, subject to costs of Rs.25,000/- to be paid by the

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CRL.M.C. 2028/2026

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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 20/07/2026 at 11:17:44

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petitioners to the Delhi High Court Bar Association Costs Account [A/C No.15530110179338; IFSC No. UCBA0001553; UCO Bank, Delhi High Court Branch] within a period of two weeks from today.

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Having regard to the circumstances giving rise to the impugned FIR and the nature of allegations therein, I am of the view the present case warrants the imposition of community service upon the petitioners. The petitioners are further directed to report to the Medical Superintendent, Safdarjung Hospital, New Delhi, on 24.07.2026 at 11:00 a.m. for this purpose. The Medical Superintendent is requested to assign suitable duties to the petitioners, either collectively or individually, for a total of four sessions of three hours each, to be completed within two months thereafter. Upon completion of the community service, the Medical Superintendent is requested to issue a certificate of compliance. The petitioners shall place the said certificate on record within two weeks thereafter.

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The parties shall remain bound by the terms of the settlement. 19. The petition, alongwith pending applications, accordingly stands disposed of.

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PRATEEK JALAN, J

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JULY 17, 2026 ‘B’/MK/SD/

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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 20/07/2026 at 11:17:44

Shri Harpreet Singh & Ors. v. the State (Govt of NCT of Delhi) & Anr.

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Shri Harpreet Singh & Ors. v. the State (Govt of NCT of Delhi) & Anr.

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