Allowed¶13

Sandeep v. State of Haryana and Another

Punjab & Haryana HC18 Mar 2026CRM-M/5933/2026

Case brief

AI extract

What is this about?

Quashing of FIR on compromise; petition under Section 528 BNSS allowed; FIR No.760 dated 22.10.2025, PS City Hansi, Sections 125 A, 281, 324(4) BNS quashed qua petitioner; SDJM Hansi report dated 12.02.2026; compromise genuine, no undue influence or coercion; one accused, not proclaimed offender; Kulwinder Singh 2007 (3) RCR (Criminal) 1052 (Full Bench) and Gian Singh 2012 (4) RCR (Criminal) 543 relied on; Section 482 Cr.P.C. inherent power; non-compoundable offences; ends of justice; not confined to matrimonial disputes.

What did the court decide?

Quashing of FIR No.760 dated 22.10.2025 registered at Police Station City Hansi under Sections 125 A, 281, 324(4) BNS, and all consequential proceedings arising therefrom, qua the petitioner, on the basis of the compromise. ¶13

Sandeep Vs State of Haryana and Another — Punjab & Haryana HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

¶13

Issue for consideration

Whether FIR No.760 dated 22.10.2025 registered at Police Station City Hansi under Sections 125 A, 281, 324(4) BNS, and the proceedings arising therefrom, should be quashed on the basis of the compromise between the parties. +1 more

¶1

Court's answer

In view of the afore-referred judgments and perusing the trial Court's report of amicable settlement, the Court found that quashing the FIR will accord a quietus to all disputes between the parties and is in the interest of both sides.

¶12

Ratio / Principle

No useful purpose would be served in continuing the proceedings; in order to secure the ends of justice, the criminal proceedings in the present case deserve to be quashed.

¶12

Key takeaways

The power of quashing on the basis of a compromise is not confined to matrimonial disputes alone.ratio¶7
Relying on the trial Court's report, the compromise was treated as genuine, without undue influence or coercion, with the sole accused not having been declared a proclaimed offender.ratio¶4
The petition is allowed: FIR No.760 dated 22.10.2025 (PS City Hansi) under Sections 125 A, 281, 324(4) BNS and all consequential proceedings arising therefrom are quashed qua the petitioner on the basis of the compromise.ratio

Detailed headnote1 paragraphs

Petition under Section 528 BNSS for quashing of FIR No.760 dated 22.10.2025, Police Station City Hansi, under Sections 125 A, 281, 324(4) BNS, on the basis of a compromise between the parties. On notice of motion (order dated 03.02.2026) the parties appeared before the trial Court/Illaqa Magistrate; the Sub Divisional Judicial Magistrate, Hansi reported (12.02.2026) that statements were recorded, the persons concerned stated the matter stood settled with no objection to quashing, the compromise was genuine and without undue influence or coercion, and the sole accused was not a proclaimed offender. Relying on the Full Bench decision in Kulwinder Singh (2007 (3) RCR (Criminal) 1052) and Gian Singh (2012 (4) RCR (Criminal) 543), the Court applied the position that the inherent power under Section 482 Cr.P.C. permits quashing of proceedings, including non-compoundable offences, on a genuine compromise to secure the ends of justice or prevent abuse of process, and is not confined to matrimonial disputes. Holding that quashing would accord a quietus to all disputes and that no useful purpose would be served in continuing the proceedings, the petition was allowed and the FIR and all consequential proceedings were quashed qua the petitioner.

¶1

1. This petition has been filed under Section 528 BNSS for quashing o f FIR No.760 dated 22.10.202 5 , registered at Police Station City Hansi, under Sections 125 A, 281, 3 2 4(4) BNS, and all subsequent proceeding s arising therefrom on the basis o f the compromise.

¶2

This Court while issuing noti c e of motion vide order dated 03.02.2026 , directed the parties to appea r before the trial Court/Illaqa Magistrate f or recording their statements w i th regard to the compromise. 3. Pursuant to the aforesaid ord e r, report dated 12.02.2026 has been recei v ed from the Sub Divisional J udicial Magistrate, Hansi. A perusal of t h e said report reveals that state m ents of the concerned persons have been r ecorded in the present case, w ho have stated that the matter has been settled between them and they ha v e no objection in case the FIR in question is quashed. The compromise ef f ected between them is

¶3

PARVEEN KUMAR 2026.03.18 18:45 I attest to the accuracy and integrity of this order/judgment.

¶4

genuine, without any undue influence and coercion. It is stated in the report that there is only 1 accused, who has not been declared as proclaimed offender.

¶5

Heard learned counsel for the parties and also gone through the case file.

¶6

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.

¶7

This power of quashing is not confined to matrimonial disputes alone. 6. Hon'ble the Supreme Court of India in the case of Gian

¶8

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:-

¶9

“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.

¶10

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 ”

¶11

PARVEEN KUMAR 2026.03.18 18:45 I attest to the accuracy and integrity of this order/judgment.

¶12

7. In view of the afore-referred judgments, perusing the report of the trial Court regarding amicable settlement between the petitioner and the complainant, this Court finds that 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. 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.

¶13

8. Resultantly, the present petition is allowed and FIR No.760 dated 22.10.2025, registered at Police Station City Hansi, under Sections 125 A, 281, 324(4) BNS, and all other consequential proceedings arising therefrom are quashed qua the petitioner on the basis of the compromise.

¶14

PARVEEN KUMAR 2026.03.18 18:45 I attest to the accuracy and integrity of this order/judgment.

Sandeep v. State of Haryana and Another

Case brief

What is this about?

What did the court decide?

Sandeep v. State of Haryana and Another

Case brief

What is this about?

What did the court decide?

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What the court decided

Issues for consideration

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Procedural history

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