Satpal Bajaj Vs the State NCT of Delhi and Ors.

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$~67

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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+ CRL.M.C. 4736/2026 SATPAL BAJAJ .....Petitioner

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Through: Mr. Ytharth Kumar and Ms. Bhumi Sharma, Advs. Petitioner in Person ( through VC )

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versus

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THE STATE NCT OF DELHI AND ORS .....Respondents Through: Mr. Naresh Kumar Chahar, APP Ms. Seema Singh, Mr. Dayanand Sharma, Advs. for R-2 and 3. R2 and R3 in person ( through VC ) SI Anju, HC Neeraj, PS KM Pur W/SI Roveine, PS Malviya Nagar

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CORAM: HON'BLE MS. JUSTICE MADHU JAIN

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O R D E R

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% 20.07.2026

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This hearing has been done through hybrid mode.

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By the way of the present petition, the petitioner is seeking quashing of FIR No. 188/2025 , registered at Police Station K.M. Pur, for the offences punishable under Sections 209 of the Bharatiya Nyaya Sanhita, 2023 (hereinafter referred to as the ‘ BNS ’) (erstwhile Section 174A of the Indian Pendal Code, 1860 hereinafter referred to as ‘ IPC’ ) and all consequential proceedings emanating therefrom on the basis of the settlement arrived at between the parties.

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Issue notice. The learned APP accepts notice on behalf of the State.

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The petitioner and the respondents are present before this Court through Video Conferencing and have been identified by their counsel and Investigating Officer (IO) .

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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 24/07/2026 at 12:04:17

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The FIR arose in connection with a series of disputes between the petitioner and respondent nos. 2 and 3, including multiple complaints under Section 138 of the Negotiable Instruments Act, 1881 (hereinafter referred to as ‘ NI Act’ ) FIRs and civil proceedings.

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On a query made by this Court, the respondents who have been identified by the IO, have categorically stated that they have entered into compromise, vide Settlement Agreement dated 24.04.2026, out of their own free will and without any pressure, coercion or threat. Therefore, they have no objection if the present FIR is quashed.

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Learned counsel for the petitioner has placed on record, the judgement of co-ordinate Bench of the Punjab and Haryana High Court dated 22.10.2024 in Jarnail Singh Bajwa v. State of Punjab , in support of his plea that if the main offence is compounded, the court can take a lenient view to quash the FIR even under Section 174A IPC (corresponding to Section 209 BNS). 8. It is noted that a Coordinate Bench of this Court, in Sohrab Hussain v. State (NCT of Delhi) & Anr. , decided on 25.05.2022, while following the earlier decision in Noor Salim Rana & Ors. v. State (Govt. of NCT of Delhi) & Anr. , decided on 22.01.2016, observed that continuation of the criminal proceedings despite an amicable settlement between the parties would be contrary to securing the ends of justice. The relevant observations are as under:

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“ It is a well settled law that where the High Court is convinced that the offences are entirely personal in nature and therefore do not affect public peace or tranquillity and where it feels that quashing of such proceedings on account of compromise would bring about peace and would secure ends of justice, it should not hesitate to quash them. In such cases, pursuing prosecution would be waste

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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 24/07/2026 at 12:04:17

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of time and energy . Non compoundable offences are basically an obstruction in entering into compromise. In certain cases, the main offence is compoundable but the connected offences are not. In the case of B.S. Joshi and others v. State of Haryana and another 2003 (4) SCC 675 the Hon’ble Apex Court observed that even though the provisions of Section 320 Cr.P.C. would not apply to such offences which are not compoundable, it did not limit or affect the powers under Section 482 Cr.P.C. The Hon’ble Apex Court laid down that if for the purpose of securing the ends of justice, quashing of FIR becomes necessary, section 320 Cr.P.C. would not be a bar to the exercise of power of quashing. ”

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In view of the above, that the parties have amicably resolved their differences out of their own free will, and without any coercion, no useful purpose will be served by continuing the proceedings, rather the same would create further acrimony between them. It would thus be in interest of justice to quash the abovementioned FIR and the proceedings pursuant thereto. There is no legal impediment in quashing the FIR in question.

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Accordingly, FIR No. 187/2025 , registered at Police Station K.M. Pur for the offences punishable under Section 209 of the BNS, along with all consequential proceedings emanating therefrom, is hereby quashed.

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The present petition is disposed of.

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Pending application(s), if any, also stand(s) disposed of.

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The order be uploaded on the website forthwith.

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MADHU JAIN, J

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JULY 20, 2026 /ys/Av

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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 24/07/2026 at 12:04:17

Satpal Bajaj v. the State NCT of Delhi and Ors.

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Satpal Bajaj v. the State NCT of Delhi and Ors.

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