Amit Bali & Anr. Vs the State NCT of Delhi and Anr.

By way of the present petition under Article 226 of the Constitution, the petitioners seek quashing of FIR No. 220/2017 dated 07.05.2017, registered at Police Station Vasant Kunj (North), District South, New Delhi, under Sections 323/341/506/34 of the Indian Penal Code, 1860 [“IPC”], alongwith all consequential proceedings emanating therefrom, on the ground of settlement.

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The parties are residents of neighbouring localities. The allegations, as emerging from the impugned FIR, are that at around 5:005:30 PM on 07.05.2017, when the complainant [respondent No. 2 herein] and his brother were drinking juice in the market, the accused persons [petitioners herein] allegedly took a baseball stick from his brother’s hand and began hitting him. Upon completion of investigation, a chargesheet was also filed.

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The parties have since resolved their disputes amicably, as

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W.P.(CRL) 278/2026 Page 1 of 5

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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 23/03/2026 at 11:41:59

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recorded in a Compromise/Settlement Deed dated 09.12.2024. In light of the aforesaid, they seek quashing of the impugned FIR.

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The petitioners are present in Court and have been identified by their learned counsel as well as by the Investigating Officer. Respondent No. 2 is also present in person, and has been identified by the Investigating Officer. He declines the assistance of counsel.

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The settlement records that the disputes between the parties arose from a misunderstanding, and have since been resolved amicably. Further, upon a specific query by the Court in this regard, respondent No.2 reiterated the same position.

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Mr. Anand V. Khatri, learned Additional Standing Counsel for the State, states that the Medico-Legal Certificate records a simple injury caused by a blunt object, implicated with a baseball bat, with no use of firearms or sharp weapons.

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The parties confirm that the settlement has been entered into voluntarily, and without any coercion, undue influence, or pressure of any kind.

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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. [(2012) 10 SCC 303], which held as follows:

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“ 58. Where the High Court quashes a criminal proceeding having

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W.P.(CRL) 278/2026 Page 2 of 5

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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 23/03/2026 at 11:41:59

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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 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. ”

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[Emphasis supplied.]

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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:

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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

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W.P.(CRL) 278/2026 Page 3 of 5

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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 23/03/2026 at 11:41:59

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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 :

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(i) ends of justice, or

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(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 .”

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[Emphasis supplied.]

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The present matter arises out of a misunderstanding between parties who reside in neighbouring localities. Applying the principles laid down by the Supreme Court, it is pertinent to note that respondent No. 2 has affirmed the voluntary nature of the settlement before the Court. Accordingly, having regard to the nature of the dispute, the simple

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W.P.(CRL) 278/2026 Page 4 of 5

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This is a digitally signed order.

¶45

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 23/03/2026 at 11:41:59

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injuries involved, the absence of any larger societal impact, and the voluntary settlement arrived at between the parties, I am of the view that the continuation of the criminal proceedings would serve no useful purpose and is unlikely to culminate in a conviction. Rather, it would result in an unnecessary expenditure of judicial time and impede the restoration of harmony between the parties.

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In view of the aforesaid, the petition is allowed, and FIR No. 220/2017 dated 07.05.2017, registered at Police Station Vasant Kunj (North), District South, New Delhi, under Sections 323/341/506/34 of the IPC, alongwith all consequential proceedings arising therefrom, is hereby quashed.

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However, having regard to the circumstances giving rise to the impugned FIR, the petitioners are directed to pay litigation costs of Rs.5,000/- each to respondent No. 2. Further, in view of the time spent in legal proceedings, the petitioners are also directed to deposit costs of Rs. 5,000/- each with the Delhi High Court Bar Association [ A/C No. 15530110179338, IFSC No. UCBA0001553, Bank Name: UCO Bank, Branch: Delhi High Court ].

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The costs be paid/deposited within two weeks from today. An affidavit of compliance be filed within two weeks thereafter.

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

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The petition stands disposed of.

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PRATEEK JALAN, J

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MARCH 16, 2026 ‘ Bhupi/KA’/

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W.P.(CRL) 278/2026 Page 5 of 5

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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 23/03/2026 at 11:41:59

Amit Bali & Anr. v. the State NCT of Delhi and Anr.

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Amit Bali & Anr. v. the State NCT of Delhi and Anr.

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