Dalbir Kaur and Others Vs State of Punjab and Another — Punjab & Haryana HC (2026) — LawSathi Research

Dalbir Kaur and Others Vs State of Punjab and Another — Punjab & Haryana HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Quashing of FIR No. 87 dated 10.07.2024 registered under Sections 329(3), 324(4), 326(e) and 3(5) of Bharatiya Nyaya Sanhita, 2023 at Police Station Sirhali, District Tarn Taran, and all the subsequent proceedings arising therefrom, qua the petitioners, on the basis of compromise dated 16.02.2026 (Annexure P-2).

Issue for consideration

Whether FIR No. 87 dated 10.07.2024 registered under Sections 329(3), 324(4), 326(e) and 3(5) of BNS at Police Station Sirhali, District Tarn Taran, and all subsequent proceedings arising therefrom, should be quashed on the basis of the compromise dated 16.02.2026 arrived at between the parties.

Court's answer

Since the parties appeared before the learned Judicial Magistrate Ist Class, Tarn Taran, their statements were recorded, and the Magistrate's report dated 20.05.2026 established that the compromise was effected voluntarily and without coercion or undue influence, and neither the State counsel nor counsel for respondent No.2 disputed the factum of compromise, no useful purpose would be served by continuing the proceedings before the trial Court in the instant FIR.

Ratio / Principle

Following the principles laid down by the Full Bench of this Court in Kulwinder Singh (2007 (3) RCR (Criminal) 1052) and approved by the Hon'ble Supreme Court in Gian Singh ((2012) 10 SCC 303), the petition is allowed and FIR No. 87 dated 10.07.2024 and all subsequent proceedings arising therefrom are quashed qua the petitioners on the basis of compromise dated 16.02.2026.

Detailed headnote1 paragraphs

Quashing of FIR on the basis of compromise — Petition under Section 528 of Bharatiya Nagrik Suraksha Sanhita, 2023 for quashing FIR No. 87 dated 10.07.2024, registered under Sections 329(3), 324(4), 326(e) and 3(5) of Bharatiya Nyaya Sanhita, 2023 at Police Station Sirhali, District Tarn Taran, and all subsequent proceedings arising therefrom, on the basis of compromise dated 16.02.2026 — Pursuant to order dated 16.04.2026, parties appeared before the learned Judicial Magistrate Ist Class, Tarn Taran and got their statements recorded; Magistrate's report dated 20.05.2026 recorded that the compromise was effected voluntarily and without any coercion or undue influence — Neither learned State counsel nor counsel for respondent No.2 disputed the factum of compromise — Following the Full Bench principles in Kulwinder Singh v. State of Punjab, 2007 (3) RCR (Criminal) 1052, approved by the Hon'ble Supreme Court in Gian Singh v. State of Punjab, (2012) 10 SCC 303, FIR No. 87 dated 10.07.2024 and all subsequent proceedings arising therefrom quashed qua the petitioners.

CRM-M-20197-2026 -1-

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

260 CRM-M-20197-2026 Date of decision: 25^th May, 2026

Dalbir Kaur and others

...Petitioners

Versus

State of Punjab and another

...Respondents

CORAM: HON'BLE MRS. JUSTICE MANISHA BATRA

Present: Mr. Anirudh Gupta, Advocate for the petitioners. (through VC)

Mr. Durgesh Garg, Assistant Advocate General, Punjab.

Mr. Ankit Kharbanda, Advocate for respondent No.2 (through VC)

MANISHA BATRA, J (ORAL):-

The present petition has been filed under Section 528 of Bharatiya Nagrik Suraksha Sanhita, 2023 (for short-‘BNSS’) for quashing of FIR No. 87 dated 10.07.2024 registered under Sections 329(3), 324(4), 326(e) and 3(5) of Bharatiya Nyaya Sanhita, 2023 (for short ‘BNS’) at Police Station Sirhali, District Tarn Taran and all the subsequent proceedings arising therefrom, on the basis of compromise dated 16.02.2026 (Annexure P-2). 2 . This Court vide order dated 16.04.2026 had directed the parties to appear before the trial Court to get their statements recorded and the learned Magistrate was directed to send its report qua the genuineness of the compromise.

PARVEEN SHARMA 2026.05.26 10:21 I attest to the accuracy and integrity of this document

CRM-M-20197-2026 -2-

Pursuant to the aforesaid order, parties have appeared before the learned Judicial Magistrate Ist Class, Tarn Taran and got their statements recorded. On the basis of the statements so recorded, learned Judge has submitted report dated 20.05.2026 to the effect that the compromise has been effected between the parties voluntarily and without any coercion or undue influence.

Learned State counsel as well as counsel for respondent No.2 have not disputed the factum of compromise between the parties.

In view of the above, no useful purpose would be served to continue with the proceedings before the trial Court in the instant FIR.

Following the principles laid down by the Full Bench judgment of this Court in Kulwinder Singh and others Versus State of Punjab and another 2007 (3) RCR (Criminal) 1052 and approved by the Hon’ble Supreme Court in Gian Singh Versus State of Punjab and others (2012) 10 SCC 303 , this petition is allowed and FIR No. 87 dated 10.07.2024 registered under Sections 329(3), 324(4), 326(e) and 3(5) of Bharatiya Nyaya Sanhita, 2023 (for short ‘BNS’) at Police Station Sirhali, District Tarn Taran and all the subsequent proceedings arising therefrom, on the basis of compromise dated 16.02.2026 (Annexure P-2) are quashed qua the petitioners.

[MANISHA BATRA] JUDGE

25^th May, 2026 Parveen Sharma

1. Whether speaking/ reasoned : Yes / No 2. Whether reportable : Yes / No

PARVEEN SHARMA 2026.05.26 10:21 I attest to the accuracy and integrity of this document