Allowed

Abhijit Muralidhar & Ors. v. State of NCT of Delhi & Anr.

Delhi HC16 Sept 2026CRL.M.C./6793/2026

Case brief

AI extract

What is this about?

The Delhi High Court quashed an FIR registered under Sections 420/34 IPC for cheating after the complainant and the accused reached a voluntary settlement. The complainant confirmed receipt of the settlement amount of Rs. 20 lakh and had no objection to quashing. Relying on Gian Singh and Narinder Singh, the court held that the dispute was essentially civil and financial in nature, with no overriding public interest, and continuation of proceedings would be futile.

What did the court decide?

FIR No. 395/2025 and all consequential proceedings quashed.

Abhijit Muralidhar & Ors. Vs State of NCT of Delhi & Anr. — Quashing and FIR | Delhi HC (2026)

¶1

$~101-Q

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

CNR No. DLHC010434332026

¶4

- CRL.M.C. 6793/2026 & CRL.M.As. 28402-28405/2026

¶5

ABHIJIT MURALIDHAR & ORS. .....Petitioners Through: Mr. Md. Imran Ahmad and Mr. Manas Parashar, Advocates.

¶6

versus

¶7

STATE OF NCT OF DELHI & ANR. .....Respondents Through: Mr. Yudhvir Singh Chauhan, APP with SI Rajnish.

¶8

Mr. Utkarsh Pratap, Advocate for R2.

¶9

CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN

¶10

O R D E R

¶11

% 16.09.2026

¶12

The petitioners have filed this petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”] (corresponding to Section 482 of the Code of Criminal Procedure, 1973 [“CrPC”]) seeking quashing of FIR No. 395/2025, dated 13.11.2025, registered at Police Station Greater Kailash, District South, Delhi, under Sections 420/34 of the Indian Penal Code, 1860 [“IPC”], and all consequential proceedings emanating therefrom, on the ground of settlement.

¶13

Issue notice. Mr. Yudhvir Singh Chauhan, learned Additional Public Prosecutor, accepts notice on behalf of the State. Mr. Utkarsh Pratap, learned counsel, accepts notice on behalf of respondent No. 2 – complainant.

¶14

Page 1 of 6

¶15

CRL.M.C. 6793/2026

¶16

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 19/09/2026 at 11:10:04

¶17

Petitioner Nos. 1 to 4 are present through video conference, and have been duly identified by their learned counsel as well as the Investigating Officer. Respondent No. 2 is also present in Court, and has been identified by her learned counsel and the Investigating Officer. Petitioner Nos. 5 and 6 – companies are represented through their Authorised Representative [petitioner No. 1]. To this effect, resolutions dated 03.09.2026, authorising petitioner No. 1 to act on behalf of the respective companies, have been placed on record.

¶18

The subject FIR was registered at the instance of respondent No. 2, alleging that, in 2023, she met petitioner No. 1, who introduced himself as the Managing Director and founder of a brand called “ Trippy Goat ”, and induced her to invest money by promising guaranteed returns and business expansion. She was also introduced to the other accused persons, as the partners of petitioner No. 1. Relying on their representations, she allegedly transferred certain sums. However, the promised returns and business arrangements did not materialise, and the accused failed to refund the amounts invested. I am informed that the chargesheet has not been filed as yet.

¶19

The parties have since amicably settled their disputes, as recorded in a Memorandum of Understanding-cum-Settlement Agreement dated 30.08.2026, entered into between petitioner No. 1 and respondent No. 2. The settlement contemplates payment of a sum of Rs. 20,00,000/- by petitioner No. 1 to respondent No. 2. It further records that, upon receipt of the said amount, respondent No. 2 shall have no surviving claim against petitioner No. 1 or any of the other persons and entities named in the FIR.

¶20

Page 2 of 6

¶21

CRL.M.C. 6793/2026

¶22

This is a digitally signed order.

¶23

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 19/09/2026 at 11:10:04

¶24

I am informed that aforesaid settlement amount of Rs. 20,00,000/has been received by respondent No. 2. Respondent No. 2, who is present in Court and represented by learned counsel, states that she has noobjection to quashing of the impugned FIR in its entirety.

¶25

Learned counsel for the parties also confirm that the settlement has been entered into voluntarily and without any coercion or undue pressure. 8. In view of the aforesaid, the parties pray for quashing of the impugned FIR.

¶26

The offence under Section 420 of the IPC is compoundable. The Supreme Court has clearly held that, in certain circumstances, the High Courts, in exercise of their powers under Section 482 of the CrPC [corresponding to Section 528 of the BNSS], 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.¹ , which held as follows:

¶27

“ 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

¶28

1 (2012) 10 SCC 303.

¶29

Page 3 of 6

¶30

CRL.M.C. 6793/2026

¶31

¶32

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. ”²

¶33

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:

¶34

“ 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.

¶35

29.2. When the parties have reached the settlement and on that basis

¶36

2 Emphasis supplied.

¶37

3 (2014) 6 SCC 466.

¶38

Page 4 of 6

¶39

CRL.M.C. 6793/2026

¶40

¶41

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 either of the aforesaid two objectives .

¶42

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.

¶43

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.

¶44

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

¶45

In the present case, respondent No. 2 was induced by the petitioners to invest in their business on the assurance of high returns. The dispute, though attracting the provisions of Section 420 of the IPC, is essentially of a private and financial nature, and does not involve any element of grave criminality or overriding public interest. The parties have since amicably resolved their disputes, and respondent No. 2 has unequivocally affirmed the voluntary nature of the settlement. In these circumstances, the criminal proceedings are unlikely to result in conviction, and its continuation would be an empty formality, adding to the burden of the justice system and consuming public resources

¶46

4 Emphasis supplied.

¶47

Page 5 of 6

¶48

CRL.M.C. 6793/2026

¶49

¶50

unnecessarily.

¶51

As noted above, the settlement amount of Rs. 20,00,000/- has already been received by respondent No. 2. There is, therefore, no impediment in granting the relief sought.

¶52

Having regard to the aforesaid, the petition is allowed, and FIR No. 395/2025, dated 13.11.2025, registered at Police Station Greater Kailash, District South, Delhi, alongwith all consequential proceedings arising therefrom, is hereby quashed.

¶53

The parties shall remain bound by the terms of the settlement. 14. The petition, alongwith pending applications, accordingly, stands disposed of.

¶54

PRATEEK JALAN, J

¶55

SEPTEMBER 16, 2026 SS/KA/

¶56

Page 6 of 6

¶57

CRL.M.C. 6793/2026

¶58

This is a digitally signed order.

¶59

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 19/09/2026 at 11:10:04

Abhijit Muralidhar & Ors. v. State of NCT of Delhi & Anr.

Case brief

What is this about?

What did the court decide?

Abhijit Muralidhar & Ors. v. State of NCT of Delhi & Anr.

Case brief

What is this about?

What did the court decide?

What the court decided

A compact analysis

Issues for consideration

Cases cited

Statutes considered

Parties & counsel

Coram

Case details

Similar cases