Allowed¶22

Harwinder Singh v. State of Punjab and Anr.

Punjab & Haryana HC18 Dec 2025CRM-M/60165/2025

Case brief

AI extract

What is this about?

Compromise-based quashing of FIR No.226 dated 18.12.2023 under Sections 420 & 406 IPC, PS City-1, Sangrur, via Section 528 BNSS petition; JMFC Sangrur verification report dated 17.12.2025; reliance on Kulwinder Singh Full Bench 2007 (3) RCR (Criminal) 1052 and Gian Singh 2012 (4) RCR (Criminal) 543; ends of justice; quietus; FIR and consequential proceedings quashed qua petitioner; CRM-M-60165-2025; Justice Aman Chaudhary; decision 18.12.2025.

What did the court decide?

Quashing of FIR No.226 dated 18.12.2023 (Sections 420 & 406 IPC, PS City-1, Sangrur) and all consequential proceedings arising therefrom, qua the petitioner, on the basis of the compromise ¶22

Harwinder Singh Vs State of Punjab and Anr. — Cheating and Forgery | Punjab & Haryana HC (2025)

What the court decided

AI extract

Outcome

Quashing of FIR No.226 dated 18.12.2023 (Sections 420 & 406 IPC, PS City-1, Sangrur) and all consequential proceedings arising therefrom, qua the petitioner, on the basis of the compromise

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Issue for consideration

Whether FIR No.226 dated 18.12.2023 (Sections 420 & 406 IPC, PS City-1, Sangrur) and all subsequent proceedings arising therefrom deserve to be quashed on the basis of the compromise effected between the parties

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Court's answer

In view of the afore-referred judgments (Kulwinder Singh, Full Bench; Gian Singh, Supreme Court) and perusing the report of the trial Court regarding amicable settlement between the petitioner and the complainant, the Court found quashing of the FIR warranted

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Ratio / Principle

Quashing the FIR will accord a quietus to all disputes between the parties and it is in the interest of both sides to bury the hatchet and lead a peaceful life

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Key takeaways

No useful purpose would be served in continuing the proceedings and, in order to secure the ends of justice, the criminal proceedings in the present case deserve to be quashedratio¶21
Petition allowed; FIR No.226 dated 18.12.2023 and all other consequential proceedings arising therefrom are quashed qua the petitioner on the basis of the compromiseratio¶22

Detailed headnote1 paragraphs

Punjab & Haryana High Court (Aman Chaudhary, J., oral), CRM-M-60165-2025 (O&M), decided 18.12.2025: Petition under Section 528 BNSS to quash FIR No.226 dated 18.12.2023 (Sections 420 & 406 IPC, PS City-1, Sangrur) on the basis of compromise. On the report dated 17.12.2025 of the Judicial Magistrate Ist Class, Sangrur recording statements that the matter stood settled, the compromise was genuine and free of undue influence or coercion, and the sole accused was neither a proclaimed offender nor involved in any other FIR, and relying on Kulwinder Singh (Full Bench, 2007 (3) RCR (Criminal) 1052) and Gian Singh (SC, 2012 (4) RCR (Criminal) 543), the Court held that quashing would accord a quietus to all disputes, that continuation would serve no useful purpose, and that quashing was required to secure the ends of justice; petition allowed and FIR with all consequential proceedings quashed qua the petitioner.

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IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

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277 CRM-M-6 0 165-2025 (O & M) Date of de c ision: 18.12.2025

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HARWIN D ER SINGH ....Petitioner Versus STATE OF PUNJAB AND ANR

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...Respondents

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CORAM: H ON’BLE MR. JUSTICE AMA N CHAUDHARY

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Present : None. AMAN CHAUDHARY, J. (ORAL)

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In view of the request letter c irculated by Bar Association, the lawyers are abstaining from work. 2. This petition has been filed under Section 528 BNSS for quashing o f FIR No.226, dated 18.12.2023 , registered under Sections 420 & 406 IP C , at Police Station City-1, Sangrur and all subsequent proceeding s arising therefrom on the basis o f the compromise. 3. This Court while issuing noti c e of motion vide order dated 29.10.2025 , directed the parties to appea r before the trial Court/Illaqa Magistrate f or recording their statements w i th regard to the compromise. 4. Pursuant to the aforesaid ord e r, report dated 17.12.2025 has been recei v ed from the Judicial Magistrat e Ist Class, Sangrur. A perusal of the said report reveals that statements o f the concerned persons have been recor d ed in the present case, who have stated that the matter has been settle d between them and they have n o objection in case the FIR in question is quashed. The compromise effe c ted between them is genuine, without an y undue influence and coercion. I t is stated in the report that

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PARVEEN KUMAR 2025.12.18 14:51 I attest to the accuracy and integrity of this order/judgment.

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CRM-M-60165-2025 -2-

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there is only one accused, who has not been declared as proclaimed offender and is not involved in any other FIR.

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Perused.

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The Full Bench of this Court in Kulwinder Singh and others vs. State of Punjab, 2007 (3) RCR (Criminal) 1052, held that High Court has power under Section 482 Cr.P.C. to allow the compounding of non-compoundable offence and quash the prosecution where the High Court is of the view that the same was required to prevent the abuse of the process of law or otherwise to secure the ends of justice. This power of quashing is not confined to matrimonial disputes alone.

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Hon'ble the Supreme Court of India in the case of Gian Singh vs. State of Punjab and another, 2012 (4) RCR (Criminal) 543, had observed that in order to secure the ends of justice or to prevent the abuse of process of Court, inherent power can be used by this Court to quash criminal proceedings in which a compromise has been effected. The relevant portion of para 57 of the said judgment reads thus:-

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“57. The position that emerges from the above discussion can be summarised thus: the power of the High Court in quashing a criminal proceeding or FIR or complaint in exercise of its inherent jurisdiction is distinct and different from the power given to a criminal court for compounding the offences under Section 320 of the Code.

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Inherent power is of wide plenitude with no statutory limitation but it has to be exercised in accord with the guideline engrafted in such power viz; (i) to secure the ends of justice or (ii) to prevent abuse of the process of any Court. XXX---XXX ”

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8. In view of the afore-referred judgments, perusing the report

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of the trial Court regarding amicable settlement between the petitioner and

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the complainant, this Court finds that quashing the FIR will accord a

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PARVEEN KUMAR 2025.12.18 14:51 I attest to the accuracy and integrity of this order/judgment.

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CRM-M-60165-2025 -3-

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quietus to all disputes between the parties and it is in the interest of both sides to bury the hatchet and lead a peaceful life. Thus, no useful purpose would be served in continuing the proceedings and in order to secure the ends of justice, the criminal proceedings in the present case deserve to be quashed.

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9. Resultantly, the present petition is allowed and F IR No.226, dated 18.12.2023, registered under Sections 420 & 406 IPC, at Police Station City-1, Sangrur and all other consequential proceedings arising therefrom are quashed qua the petitioner on the basis of the compromise.

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PARVEEN KUMAR 2025.12.18 14:51 I attest to the accuracy and integrity of this order/judgment.

Harwinder Singh v. State of Punjab and Anr.

Case brief

What is this about?

What did the court decide?

Harwinder Singh v. State of Punjab and Anr.

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

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