Salwant Singh and Another v. State of Punjab and Another

Punjab & Haryana HC7 Jul 2026CRM-M/11348/2026

Case brief

AI extract

What is this about?

CRM-M No.11348 of 2026, High Court of Punjab & Haryana (Vikram Aggarwal, J., 07.07.2026): quashing of FIR No.03 dated 02.01.2022 under Sections 420/120-B IPC, PS Machhiwara, District Ludhiana, on genuine compromise dated 08.02.2026; Section 528 BNSS / Section 482 Cr.P.C. inherent powers; Judicial Magistrate 1st Class Samrala report; relies on Kulwinder Singh 2007(3) RCR (Criminal) 1052 and Gian Singh 2012(4) RCR (Crl.) 543; FIR and consequential proceedings quashed qua petitioners.

What did the court decide?

Quashing of FIR No.03 dated 02.01.2022 registered under Sections 420 and 120-B IPC at Police Station Machhiwara, District Ludhiana, and all consequential/proceedings arising therefrom, qua the petitioners. ¶¶21

Salwant Singh and Another Vs State of Punjab… — Cheating and Forgery | Punjab & Haryana HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether FIR No.03 dated 02.01.2022 registered under Sections 420 and 120-B IPC at Police Station Machhiwara, District Ludhiana, and all subsequent proceedings arising therefrom, should be quashed on the basis of the compromise dated 08.02.2026 arrived at between the petitioners and respondent No.2.

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Ratio / Principle

On the Judicial Magistrate's report, the parties effected a genuine compromise without any pressure, coercion or undue influence; the compromise was found fully in consonance with the directions in Kulwinder Singh and Gian Singh.

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Key takeaways

The inherent powers under Section 482 Cr.P.C./Section 528 BNSS can be exercised in such situations to prevent the parties facing the unnecessary vagaries of criminal trial when there are remote chances of conviction of the accused.ratio¶¶20
In view of the report of the Judicial Magistrate 1st Class, Samrala, accompanied by statements of both parties, the petition was allowed and FIR No.03 dated 02.01.2022 (Sections 420/120-B IPC, PS Machhiwara, District Ludhiana) and all consequential proceedings were quashed qua the petitioners.ratio¶¶21

Detailed headnote1 paragraphs

Quashing of FIR on the basis of compromise — Petition under Section 528 BNSS for quashing of FIR No.03 dated 02.01.2022, registered under Sections 420 and 120-B IPC at Police Station Machhiwara, District Ludhiana, on the basis of compromise dated 08.02.2026 between petitioners and respondent No.2 — Coordinate Bench ordered (08.04.2026) statements to be recorded; Judicial Magistrate 1st Class, Samrala reported (08.06.2026) that the compromise was genuine and free of pressure, coercion or undue influence — Held: powers under Section 482 Cr.P.C./528 BNSS exercisable where compromise is genuine and chances of conviction remote, sparing parties unnecessary trial; compromise in consonance with directions in Kulwinder Singh (2007(3) RCR (Criminal) 1052) and Gian Singh (2012(4) RCR (Crl.) 543) — Petition allowed; FIR and all consequential proceedings quashed qua petitioners. (Vikram Aggarwal, J., oral; decided 07.07.2026)

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285 IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

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CRM-M No.11348 of 2026 Date of Decision:-07.07.2026

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Salwant Singh and another

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…..Petitioners.

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Versus

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State of Punjab and another

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.....Respondents.

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CORAM: HON’BLE MR. JUSTICE VIKRAM AGGARWAL

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Present:Mr. Rai Singh Chauhan, Advocate for the petitioners.

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Mr. Ravneet Singh Lekhi, AAG, Punjab.

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Mr. Kripal Singh, Advocate for respondent No.2.

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VIKRAM AGGARWAL, J . (ORAL)

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The prayer in this petition preferred under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (for short the ‘BNSS’) is for quashing of FIR No.03 dated 02.01.2022 registered under Sections 420 and 120-B IPC, at Police Station Machhiwara, District Ludhiana, with all subsequent proceedings arising therefrom on the basis of a compromise dated 08.02.2026 (Annexure P-2) arrived at between the petitioners and respondent No.2.

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Vide order dated 08.04.2026, a coordinate Bench had directed the parties to appear before the Area Magistrate/trial Court for getting their statements recorded with regard to the compromise dated 08.02.2026.

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The Area Magistrate/trial Court was to submit a report in this regard giving certain details as enumerated in the said order.

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YAG DUTT 2026.07.08 18:09 I attest to the accuracy and authenticity of this order/judgment.

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CRM-M No.11348 of 2026 -2-

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Pursuant to the order dated 08.04.2026, the parties appeared before the Judicial Magistrate 1^st Class, Samrala, and as per the report dated 08.06.2026 submitted to this Court, both the parties got their respective statements recorded in Court.

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A perusal of the aforesaid report would show that the parties have effected a genuine compromise without there being any pressure, coercion or undue influence. The powers under Section 482 Cr.P.C./528 of the BNSS can be exercised in such like situations in order to prevent unnecessary vagaries of criminal trial to be faced by the parties, when there are remote chances of conviction of the accused. The compromise in question is found to be fully in consonance with the directions issued by the Court in “ Kulwinder Singh & Ors. Vs. State of Punjab 2007(3) RCR (Criminal) 1052 ” and “ Gian Singh Vs. State of Punjab & Anr., 2012(4) RCR (Crl.) 543 ”.

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In view of the aforesaid report of the Judicial Magistrate 1^st Class, Samrala, accompanied by statements of both the parties, the present petition is allowed and FIR No.03 dated 02.01.2022 registered under Sections 420 and 120-B IPC, at Police Station Machhiwara, District Ludhiana, with all consequential proceedings arising therefrom are hereby quashed qua the petitioners.

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(VIKRAM AGGARWAL) July 07, 2026 JUDGE Yag Dutt Whether speaking/reasoned: Yes/No Whether Reportable: Yes/No

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YAG DUTT 2026.07.08 18:09 I attest to the accuracy and authenticity of this order/judgment.

Salwant Singh and Another v. State of Punjab and Another

Case brief

What is this about?

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Salwant Singh and Another v. State of Punjab and Another

Case brief

What is this about?

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What the court decided

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