Allowed¶42

K.Steffy @ Manikkammal Steffy v. The State rep.by

Madras HC12 Jun 2026CRL OP/14120/2026

Case brief

AI extract

What is this about?

Quashing of FIR on amicable compromise/settlement between parties at investigation stage; offences non-compoundable yet FIR quashed; B.N.S, 2023 Sections 191(2), 296(b), 115(2), 118(1), 76, 79, 351(3) and Section 4, Tamil Nadu Prohibition of Harassment of Women Act, 2002; petition under Section 528 BNSS; jurisdiction exercised under Section 482 Cr.P.C.; reliance on Parbathbhai Aahir @ Parbathbhai (2017) 9 SCC 641 and The State of Madhya Pradesh v. Dhruv Gurjar (2019) 2 MLJ Crl 10; parties' affidavits; identity verified by Sub-Inspector; Kasimedu Police Station, Chennai; Crl.O.P.No.14120 of 2026; Madras High Court; M.Nirmal Kumar J.; 12.06.2026.

What did the court decide?

Quashing of the F.I.R in Crime No.76 of 2025 dated 01.02.2025 on the file of the first respondent Police against the petitioners. ¶42

K.Steffy @ Manikkammal Steffy Vs The State rep.by — Madras HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Quashing of the F.I.R in Crime No.76 of 2025 dated 01.02.2025 on the file of the first respondent Police against the petitioners.

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Issue for consideration

Whether the F.I.R in Crime No.76 of 2025, founded on a personal dispute since amicably settled by the parties, should be quashed notwithstanding that the offences involved are not compoundable.

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Court's answer

After enquiry, the Court was satisfied that the parties had come to an amicable settlement; the second respondent attributed the occurrence to misunderstanding and difference of opinion, described the dispute as purely personal, and both sides filed affidavits expressing unwillingness to proceed further with the case.

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Ratio / Principle

Even though the offences involved are not compoundable in nature, no useful purpose will be served in keeping the First Information Report pending once the parties have settled the dispute amicably.

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Key takeaways

In the light of the guidelines given by the Hon'ble Supreme Court in Parbathbhai Aahir @ Parbathbhai Vs. State of Gujrath, (2017) 9 SCC 641, and after exercising due caution as advised in The State of Madhya Pradesh v. Dhruv Gurjar and Another, (2019) 2 MLJ Crl 10, this Court in exercise of its jurisdiction under Section 482 Cr.P.C. was inclined to quash the F.I.R.ratio¶40
The Criminal Original Petition stands allowed and, as a sequel, the F.I.R in Crime No.76 of 2025 dated 01.02.2025 on the file of the first respondent Police is quashed against the petitioners.ratio¶42

Detailed headnote1 paragraphs

Allowed — FIR quashed on compromise. The five petitioners, accused in Crime No.76 of 2025 dated 01.02.2025 (offences under Sections 191(2), 296(b), 115(2), 118(1), 76, 79 and 351(3) of the B.N.S, 2023 and Section 4 of the Tamil Nadu Prohibition of Harassment of Women Act, 2002, Kasimedu Police Station, Chennai), filed this Criminal Original Petition under Section 528 of BNSS to quash the FIR on the ground of compromise. The case was at the investigation stage. The petitioners and the second respondent (de facto complainant) appeared before the Court, their identity was confirmed by Sub-Inspector M.Muthuraj, and both sides filed separate affidavits; the second respondent stated the occurrence arose from misunderstanding and difference of opinion, the dispute being purely personal, and the parties were unwilling to proceed further. Holding that no useful purpose would be served in keeping the First Information Report pending even though the offences involved are not compoundable in nature, and acting in the light of the guidelines in Parbathbhai Aahir @ Parbathbhai Vs. State of Gujrath, (2017) 9 SCC 641, with due caution as advised in The State of Madhya Pradesh v. Dhruv Gurjar and Another, (2019) 2 MLJ Crl 10, the Court exercised its jurisdiction under Section 482 Cr.P.C. and quashed the FIR against the petitioners. (M.NIRMAL KUMAR, J.; 12.06.2026)

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Crl.O.P.No.14120 of 2026

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED : 12.06.2026

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CORAM :

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THE HON’BLE MR.JUSTICE M.NIRMAL KUMAR

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Crl.O.P.No.14120 of 2026

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K.Steffy @ Manikkammal Steffy

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I.Clement @ I.Kanikkairaj Clement

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K.Williams

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Prema @ Alphonse Prema

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Charlton @ W.Charlton Christ

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.. Petitioners

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Versus

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The State, rep by Inspector of Police, N2-Kasimedu Police Station, Royapuram, Chennai.

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M.Irudhayamary @ Sofia

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.. Respondents

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Prayer : Criminal Original Petition filed under Section 528 of BNSS, to call for records pertaining to the F.I.R in Crime No.76 of 2025 on the file of N1-Kasimedu Police Station, Chennai and quash the same.

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For Petitioners : Mr.S.Magimai Raj For Respondents : Mr.A.Amarnath, Counsel for Government of Tamil Nadu (Criminal Side), for R1 : Mr.K.Ariprakash, for R2

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.No.14120 of 2026

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ORDER

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The petitioners, who are the accused in Crime No.76 of 2025 dated 01.02.2025 for offences under Sections 191(2), 296(b), 115(2), 118(1), 76, 79 and 351(3) of the B.N.S, 2023 and Section 4 of the Tamil Nadu Prohibition of Harassment of Women Act, 2002 on the file of the first respondent Police, have filed this Criminal Original Petition on the ground of compromise.

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The case of the petitioners is that on 22.10.2024, at 9.00 P.M, when the second respondent’s father was sitting outside their house, the petitioners came there, abused him in filthy language. When the second respondent questioned the same, the petitioners started abusing the second respondent also in filthy language and physically assaulted her. With the assistance of the neighbours, the second respondent was admitted in the Government Stanley Hospital, Chennai on 22.10.2024 at around 11.00 P.M. The first respondent Police took complaint from the second respondent. On the complaint of the second respondent, the first respondent Police registered F.I.R in Crime No.76 of 2025 for offences under Sections 191(2), 296(b), 115(2), 118(1), 76, 79 and 351(3) of the

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.No.14120 of 2026

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B.N.S, 2023 and Section 4 of the Tamil Nadu Prohibition of Harassment of Women Act, 2002 against the petitioners.

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The case is at the stage of investigation. By passage of time,

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the parties have decided to bury their hatchet and compromise the dispute amicably among themselves.

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Today, the petitioners and the second respondent appeared before this Court and their identity is confirmed by Mr.M.Muthuraj, SubInspector attached to the first respondent Police Station. This Court also enquired both the parties and was satisfied that the parties have come to an amicable settlement between themselves. The second respondent informed that due to misunderstanding and difference of opinion, the occurrence has happened and the dispute was purely personal in nature and now they are not willing to further proceed with the case and filed an affidavit to that effect. The petitioners and the second respondent have filed separate affidavit before this Court.

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Under such circumstances, no useful purpose will be served in

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keeping the First Information Report pending, even though, the offences

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.No.14120 of 2026

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involved are not compoundable in nature. In the light of the guidelines

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given by the Hon'ble Supreme Court reported in (2017) 9 SCC 641 -

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( Parbathbhai Aahir @ Parbathbhai Vs. State of Gujrath ), and after exercising due caution as advised by the Hon'ble Supreme Court in The

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State of Madhya Pradesh v. Dhruv Gurjar and Another reported in (2019) 2 MLJ Crl 10 , this Court in exercise of its jurisdiction under Section 482 Cr.P.C., is inclined to quash the F.I.R.

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