Allowed

Rajan & Ors. v. State Govt. of NCT of Delhi and Ors.

Delhi HC14 Jan 2026CRL.M.C./295/2026

Case brief

AI extract

What is this about?

Cross-FIRs by neighbours over a street scuffle, alleging simple hurt and wrongful restraint, were settled by memorandum of understanding with no-objection affidavits from complainants. The High Court exercised inherent powers to quash both FIRs and consequential proceedings.

What did the court decide?

Both cross-FIRs (Nos. 1418/2023 and 1419/2023, PS Nihal Vihar) under Sections 323/341/34 IPC quashed alongwith consequential proceedings.

Rajan & Ors. Vs State Govt. of NCT of Delhi and Ors. — Quashing and FIR | Delhi HC (2026)

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$~121 & 124

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* IN THE HIGH COURT OF DELHI AT NEW DELHI

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CRL.M.C. 225/2026 BHASKAR JHA & ANR. .....Petitioners

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versus

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STATE NCT OF DELHI & ORS. .....Respondents

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CRL.M.C. 295/2026 RAJAN & ORS. .....Petitioners

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versus

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STATE GOVT. OF NCT OF DELHI AND ORS. .....Respondents

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Appearance:- Mr. Bharat Bhushan, Ms. Jyoti Tayai, Ms. Riya Jha & Mr. Arjun Bansal, Advocates for Petitioners alongwith Petitioners in Person in Item Nos. 121 & 124. Ms. Manjeet Arya, APP for State with SI Sachin Kumar, SI Vishal, PS Gandhi Nagar.

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CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN

O R D E R

14.01.2026

The present petitions under Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 482 of Criminal Procedure Code, 1973) seek quashing of two FIRs, being FIR No. 1418/2023 [subject matter of CRL.M.C. 225/2026] [“FIR A”] and FIR No. 1419/2023 [subject matter of CRL.M.C. 295/2026] [“FIR B”], alongwith all consequential proceedings emanating therefrom, on the basis of settlement arrived at between the parties. Both FIRs are dated 02.11.2023, and were registered at Police Station Nihal Vihar, Outer

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CRL.M.C. 225/2026 & Connected Matter

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Page 1 of 4

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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 19/01/2026 at 12:07:54

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District, New Delhi, under Sections 323/341/34 of the Indian Penal Code, 1860 [“IPC”].

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Issue notice. Ms. Manjeet Arya, learned Additional Public Prosecutor, accepts notice on behalf of the State in both petitions. Notice is accepted by Mr. Bharat Bhushan, learned counsel, on behalf of the complainants in both the petitions.

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The petitions are taken up for hearing together with the consent of learned counsel for the parties.

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The cross-FIRs have been filed by neighbours against each other and arise out of the same incident dated 01.11.2023, which took place at about 01:45 P.M. in Gali No. 2, G-Block, Adhyapak Nagar, Nangloi, Delhi.

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In CRL.M.C. 225/2026, the allegation is that the petitioners were driving a vehicle through the narrow lane and started blowing the horn loudly due to obstruction caused by a rickshaw-scooty. It is alleged that upon objection by a neighbour, a verbal altercation ensued, which escalated into a physical scuffle, during which the complainants and other residents of the lane sustained injuries. On the basis of the said complaint, FIR A under Sections 323/341/34 IPC came to be registered.

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On the other hand, FIR B, which is the subject matter of CRL.M.C. 295/2026, was registered on the complaint of the petitioners in CRL.M.C. 225/2026, alleging that when the petitioners were attempting to take their vehicle out of the lane after the obstruction was removed, they were wrongfully restrained, abused and assaulted by the complainant party and other neighbours, resulting in injuries to the petitioners and their companion. On the basis of these allegations, FIR B under Sections

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CRL.M.C. 225/2026 & Connected Matter

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Page 2 of 4

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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 19/01/2026 at 12:07:54

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323/341/34 IPC was registered as a cross-case. No chargesheet has yet been filed.

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The Medico-Legal Case in both cases show simple injuries.

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During the pendency of investigation, the parties amicably resolved their disputes by way of a Memorandum of Understanding executed between the parties on 03.01.2026. Pursuant to the settlement, the complainants in both FIRs have executed Affidavits-cum-No Objection Certificates on 06.01.2026, categorically stating that they have no objection to the quashing of the two FIRs, and all proceedings arising therefrom.

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I have heard learned counsel for the parties. The parties are present before the Court and have been identified by the Investigating Officer as well as by their respective counsel. The parties confirm before the Court that they have settled their disputes and do not wish to proceed with the criminal proceedings against each other.

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It is pertinent to note that the offences under Sections 323 and 341 of IPC are compoundable, only at the instance of the aggrieved parties. However, that does not debar the High Court from resorting to its inherent power under Section 528 of BNSS (corresponding to Section 482 of CrPC) and pass an appropriate order so as to secure the ends of justice.

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Having regard to the nature of the dispute and the fact that the aggrieved parties have amicably settled the matter, this Court is of the view that continuation of the criminal proceedings would serve no useful purpose.

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The present case is one of dispute between neighbours. The parties

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CRL.M.C. 225/2026 & Connected Matter

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Page 3 of 4

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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 19/01/2026 at 12:07:54

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continue to live in the same locality and have agreed to bury the hatchet, by way of a settlement. This appears to me to be a fit case, in which inherent power of this Court can be used to quash the cross-FIRs. Such an order would permit the parties to live in peace and harmony, rather than compounding the animosity.

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The petitions are therefore allowed, and FIR A dated 02.11.2023, under Section 323/341/34 of the IPC, and FIR B dated 02.11.2023 under Section 323/341/34 of the IPC, registered at Police Station Nihal Vihar, New Delhi, are hereby quashed.

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The petitions are accordingly disposed of.

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PRATEEK JALAN, J

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JANUARY 14, 2026 ‘pv/JM’/

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CRL.M.C. 225/2026 & Connected Matter

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Page 4 of 4

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Rajan & Ors. v. State Govt. of NCT of Delhi and Ors.

Case brief

What is this about?

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Rajan & Ors. v. State Govt. of NCT of Delhi and Ors.

Case brief

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