Zulfikar & Ors. Vs State (Nct of Delhi) & Ors. — Delhi HC (2026) — LawSathi Research

Zulfikar & Ors. Vs State (Nct of Delhi) & Ors. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Quashing of both cross-FIRs (FIR No.11/26 dated 10.01.2026 and FIR No.08/26 dated 08.01.2026, Police Station Seemapuri, Sections 126(2)/115(2)/351(2)/3(5) BNS 2023) and of all consequential proceedings emanating therefrom, under Section 528 BNSS, on the basis of the settlement; both petitions disposed of accordingly.

Issue for consideration

Whether the two cross-FIRs registered at Police Station Seemapuri should be quashed, along with all consequential proceedings, on the basis of the compromise arrived at between the parties. +1 more

Court's answer

Since both parties are residents of the same locality, have amicably settled, the nature of the offence is not serious, and the dispute is primarily private with no public-interest dimension, continuing the criminal proceedings would serve no useful purpose.

Ratio / Principle

Even though the matter was pending investigation and the final opinion on the injuries had yet not been received from the hospital, the fact that both parties are residents of the same locality and have agreed to settle all their disputes in an amicable and quick manner justified terminating the criminal proceedings.

Key takeaways

Exercising the inherent powers vested in the Court under Section 528 of the BNSS, it was deemed appropriate to quash the FIR(s).ratio¶13
To secure the ends of justice, FIR No.11/2026 dated 10.01.2025 (date as printed) and FIR No.08/2026 dated 08.01.2026, registered at Police Station Seemapuri for the BNS offences, along with all consequential proceedings emanating therefrom, stand quashed.ratio¶14

Detailed headnote1 paragraphs

High Court of Delhi (Manoj Jain, J., oral judgment dated 05.02.2026) — Quashing of cross-FIRs on compromise. Two cross-cases, W.P.(CRL) 234/2026 (Zulfikar & Ors.) and W.P.(CRL) 239/2026 (Saleem Ahmad & Ors.), sought quashing of cross-FIRs No.11/26 (dt. 10.01.2026) and No.08/26 (dt. 08.01.2026), Police Station Seemapuri, under Sections 126(2)/115(2)/351(2)/3(5) Bharatiya Nyaya Sanhita, 2023 (corresponding Sections 341/323/506/34 IPC). The FIRs arose from a scuffle between residents of the same locality following a fire at one party's store; both sides sustained simple injuries. Pursuant to a Settlement Deed dated 15.01.2026, signed by all parties with mutual apologies and undertakings not to pursue their respective cases, and the respondents being identified by the Investigating Officer, the Court held that although the matter was pending investigation and the final injury opinion had not been received from the hospital, the offences being not serious and the dispute being primarily private with no public-interest element, continuing the criminal proceedings would serve no useful purpose. Exercising inherent powers under Section 528 BNSS, the Court quashed both FIRs and all consequential proceedings emanating therefrom, to secure the ends of justice; the petitions stood disposed of.

$~41 & 42

IN THE HIGH COURT OF DELHI AT NEW DELHI

% Date of Decision: 5^th February, 2026

W.P.(CRL) 234/2026 ZULFIKAR & ORS. .....Petitioners Through: Mr. Mohd. Ajmal, Advocate with petitioners in person

versus

STATE (NCT OF DELHI) & ORS. .....Respondents Through: Mr. Sanjay Lao, Standing Counsel (Crl.) with Mr. Aryan Sachdeva, Advocate for State SI Vijay, P.S. Seemapuri. Mr. Mohd. Shariq with Mr. Rishi Vohra and Mr. Amit Kharbanda, Advocates for respondent Nos.2 and 3 with Respondent Nos.2 and 3 in person.

- W.P.(CRL) 239/2026 SALEEM AHMAD & ORS. .....Petitioners Through: Mr. Mohd. Shariq with Mr. Rishi Vohra and Mr. Amit Kharbanda, Advocates with petitioners in person

versus

STATE (NCT OF DELHI) & ORS. .....Respondents Through: Mr. Sanjay Lao, Standing Counsel (Crl.) with Mr. Aryan Sachdeva, Advocate for State SI Vijay, P.S. Seemapuri. Mr. Mohd. Ajmal, Advocate for respondent Nos.2 to 6 with respondent Nos.2 to 6 in person.

CORAM:

HON’BLE MR. JUSTICE MANOJ JAIN J U D G M E N T (oral)

There are two cross-cases and the abovesaid two petitions have been

Signature Not Verified

W.P.(CRL) 234/2026 & W.P.(CRL) 239/2026

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Signed By:SONIA THAPLIYAL Signing Da te:0 7.02.2026 12:29:43

filed seeking quashing of both such cross-FIRs

In W.P.(CRL) 234/2026, all the three petitioners seek quashing of FIR No.11/26, dated 10.01.2026, registered at Police Station Seemapuri for commission of offences under Sections 126(2)/115(2)/351(2)/3(5) Bharatiya Nyaya Sanhita (BNS), 2023 (corresponding Sections 341/323/506/34 IPC), along with all consequential proceedings arising therefrom, on the basis of compromise arrived at between the parties.

The alleged injured i.e. respondent No.2 - Saleem Ahmad is present in Court and respondent No.3 - Saqib Qureshi has joined the proceedings through video-conferencing.

In W.P.(CRL) 239/2026, all the six petitioners seek quashing of FIR No.08/26, dated 08.01.2026, registered at Police Station Seemapuri for commission of offences under Sections 126(2)/115(2)/351(2)/3(5) Bharatiya Nyaya Sanhita (BNS), 2023 (corresponding Sections 341/323/506/34 IPC), along with all consequential proceedings arising therefrom, on the basis of compromise arrived at between the parties. It has been filed by all the six accused persons and all the five injured persons have been arraigned as respondent Nos.2 to 6. All the injured, expect respondent No.6 – Shakil, are present physically. Respondent No.6 - Shakil has joined the proceedings through video-conferencing.

The matter is very recent and the FIR was registered on 08.01.2026. On the date of the incident, there was a fire in the store of Mr. Salim Ahmad (respondent No.2 in W.P.(Crl.) 234/2026) and on account of such fire, there was a commotion and quarrel and both the sides, who are residents of the same locality, entered into scuffle.

Both the sides sustained simple injuries and since both the parties had

Signature Not Verified

W.P.(CRL) 234/2026 & W.P.(CRL) 239/2026

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Signed By:SONIA THAPLIYAL Signing Da te:0 7.02.2026 12:29:43

reported the matter to the police, the abovesaid two FIRs were registered.

The matter has now been amicably settled.

Copy of Settlement Deed dated 15.01.2026 has also been placed on record, which mentions that the parties are the residents of the same locality and on account of intervention of family members, relatives, friends and respectable members of Society, a meeting was held where they had agreed to settle their disputes to live peacefully. Both the parties have apologized to each other and undertake not to pursue with their respective cases.

The Settlement Deed is signed by all concerned. The affidavits of injured persons have also been placed on record. 10. The respondents in both the petitions are duly identified by the Investigating Officer, who is present in Court.

The Investigating Officer, while identifying them, submits that the matter is pending investigation and the final opinion with respect to the injuries received by the concerned injured persons has yet not been received from the concerned hospital. 12. Be that as it may, fact remains that both the parties are residents of the same locality and have agreed to settle all their disputes in an amicable and quick manner. Moreover, the nature of offence is also not very serious and therefore, continuing with criminal proceedings would serve no useful purpose, especially, when dispute does not involve any public interest and is, primarily, private in nature.

Accordingly, exercising inherent powers vested in this Court under Section 528 of the BNSS, it is deemed appropriate to quash the instant FIR. 14. Consequently, to secure the ends of justice, FIR No.11/2026 dated 10.01.2025 and FIR No.08/2026 dated 08.01.2026, registered at Police

Signature Not Verified

W.P.(CRL) 234/2026 & W.P.(CRL) 239/2026

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Signed By:SONIA THAPLIYAL Signing Da te:0 7.02.2026 12:29:43

Station Seemapuri for commission of offences under Sections 126(2)/115(2)/351(2)/3(5) Bharatiya Nyaya Sanhita (BNS), 2023 , along with all consequential proceedings emanating therefrom, are hereby, quashed. 15. The petitions stand disposed of in aforesaid terms.

(MANOJ JAIN) JUDGE

FEBRUARY 5, 2026 st/js

Signature Not Verified

W.P.(CRL) 234/2026 & Signed By:SONIA THAPLIYAL W.P.(CRL) 239/2026 Signing Da te:0 7.02.2026 12:29:43

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