Quashed¶37

Saleem Ahmad & Ors. v. State (Nct of Delhi) & Ors.

Delhi HC5 Feb 2026W.P.(CRL)/239/2026

Case brief

AI extract

What is this about?

Keywords: quashing of FIR on compromise/settlement deed; cross-cases/cross-FIRs; inherent powers under Section 528 BNSS; Sections 126(2)/115(2)/351(2)/3(5) BNS 2023; corresponding Sections 341/323/506/34 IPC; Police Station Seemapuri; Settlement Deed dated 15.01.2026; simple injuries both sides; dispute private in nature, no public interest; W.P.(CRL) 234/2026 & W.P.(CRL) 239/2026; High Court of Delhi; Manoj Jain, J.; appearance through video-conferencing; affidavits of injured persons.

What did the court decide?

FIR No.11/2026 dated 10.01.2025 (sic; pleaded as 10.01.2026) and FIR No.08/2026 dated 08.01.2026, registered at Police Station Seemapuri for offences under Sections 126(2)/115(2)/351(2)/3(5) BNS, 2023, along with all consequential proceedings emanating therefrom, quashed; both petitions stand disposed of. ¶37

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

What the court decided

AI extract

Outcome

¶37

Issue for consideration

Whether the two cross-FIRs — FIR No.11/26 dated 10.01.2026 and FIR No.08/26 dated 08.01.2026, both registered at Police Station Seemapuri under Sections 126(2)/115(2)/351(2)/3(5) BNS, 2023 — together with all consequential proceedings, ought to be quashed on the basis of the compromise arrived at between the parties.

¶17

Court's answer

In view of the amicable settlement between the parties, the non-serious nature of the offence, and the fact that the dispute does not involve any public interest and is primarily private in nature, the Court, exercising its inherent powers under Section 528 of the BNSS, deemed it appropriate to quash the FIRs.

¶32

Ratio / Principle

Continuing with criminal proceedings would serve no useful purpose where the dispute, though resulting in simple injuries to both sides, does not involve any public interest and is primarily private in nature.

¶31

Detailed headnote1 paragraphs

Delhi High Court (Manoj Jain, J., oral) quashed two cross-FIRs — No.11/26 dated 10.01.2026 and No.08/26 dated 08.01.2026, both of P.S. Seemapuri, for offences under Ss.126(2)/115(2)/351(2)/3(5) Bharatiya Nyaya Sanhita, 2023 (corresponding Ss.341/323/506/34 IPC) — under S.528 BNSS. The cross-cases arose from a quarrel/scuffle on 08.01.2026 following a fire in the store of Mr. Salim Ahmad; both sides sustained simple injuries. Pursuant to a Settlement Deed dated 15.01.2026 (signed by all concerned, supported by affidavits of the injured), the neighbouring parties agreed to settle all disputes. The Court held that the offence was not serious, the dispute was primarily private with no public interest involved, and continuing the criminal proceedings would serve no useful purpose; both FIRs and consequential proceedings were quashed and the writ petitions disposed of.

¶1

$~41 & 42

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

% Date of Decision: 5^th February, 2026

¶4

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

¶5

versus

¶6

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.

¶7

- 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

¶8

versus

¶9

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.

¶10

CORAM:

¶11

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

¶12

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

¶13

Signature Not Verified

¶14

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

¶15

¶16

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

¶17

filed seeking quashing of both such cross-FIRs

¶18

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.

¶19

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.

¶20

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.

¶21

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.

¶22

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

¶23

Signature Not Verified

¶24

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

¶25

¶26

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

¶27

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

¶28

The matter has now been amicably settled.

¶29

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.

¶30

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.

¶31

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.

¶32

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

¶33

Signature Not Verified

¶34

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

¶35

¶36

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

¶37

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.

¶38

(MANOJ JAIN) JUDGE

¶39

FEBRUARY 5, 2026 st/js

¶40

Signature Not Verified

¶41

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

¶42

Saleem Ahmad & Ors. v. State (Nct of Delhi) & Ors.

Case brief

What is this about?

What did the court decide?

Saleem Ahmad & Ors. v. State (Nct of Delhi) & Ors.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Ajay Saxena Vs State Govt. of NCT of Delhi & Anr.

Anjali & Anr. Vs State of Nctof Delhi & Ors.

Jeet Dahiya Vs State of NCT of Delhi

Rajesh and Ors. Vs State NCT of Delhi and Anr.

Siddharth @ Raja Vs State (Nct of Delhi)

M/S Semma Imports Vs Union of India & Ors.

Karan Panwar and Ors. Vs State NCT of Delhi and Anr.

Rana Pratap Singh Vs State of NCT of Delhi & Anr.

Chotu Yadav Vs the State NCT of Delhi

Anjali & Anr. Vs State of Nctof Delhi & Ors.

Yakub Chaudhary Vs State (Govt. of NCT of Delhi)

Lakshmi Jatav & Ors. Vs State Govt. of NCT of Delhi and Anr.

Sunny Vs the State of NCT of Delhi

Sri Vasavi Industries Limited Vs Pec Limited & Ors.