A petition under Section 528 BNSS sought quashing of an FIR alleging misuse of signatures to procure a loan, arising from matrimonial and business disputes. The parties settled all disputes by deed; respondent affirmed voluntary settlement. The court relied on Gian Singh and Narinder Singh and quashed the FIR and consequential proceedings.
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$~66 Q
versus
STATE NCT OF DELHI, & ANR. .....Respondent Through: Mr. Hitesh Vali, APP for State. Mr. Aryan Sharma, Advocate for R-2 alongwith R-2 in Person (VC).
CORAM:
HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R
CRL.M.C. 4391/2026
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taken up for hearing.
CRL.M.C. 4391/2026
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16.05.2026.
CRL.M.C. 4391/2026
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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 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
1 (2012) 10 SCC 303.
CRL.M.C. 4391/2026
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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 11:18:18
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. ”2
Further, in Narinder Singh and Ors. v. State of Punjab and 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:
“ 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: 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.
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 . While exercising the power the High Court is to form an opinion on
2 Emphasis supplied.
3 (2014) 6 SCC 466.
CRL.M.C. 4391/2026
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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 11:18:18
either of the aforesaid two objectives .
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.
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 .
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
4 Emphasis supplied.
CRL.M.C. 4391/2026
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PRATEEK JALAN, J
JULY 16, 2026 ‘pv’ /SD/
CRL.M.C. 4391/2026
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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 11:18:18
1 issue framed by the court
Whether an FIR for cheating and conspiracy arising from matrimonial and financial disputes can be quashed on the basis of a voluntary settlement between the parties.
Colour shows how this judgement treated each authority
Gian Singh v. State of Punjab and Anr.Relied on¶11
(2012) 10 SCC 303 · Who else cites this
Narinder Singh and Ors. v. State of Punjab and Anr.Relied on¶11
(2014) 6 SCC 466 · Who else cites this
3 provisions across 2 enactments
Tanvir Singh
State NCT of Delhi
Respondent No. 2
Prateek Jalan
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
