Allowed¶15

Vishal Mittal and Others v. State of Punjab and Another

Punjab & Haryana HC23 Jan 2026CRM-M/64034/2025

Case brief

AI extract

What is this about?

Quashing of FIR on basis of compromise; BNS 2023 Sections 126(2), 115(2), 351(2), 324(4), 191(3), 190; Section 482 Cr.P.C. inherent power; Kulwinder Singh 2007 (3) RCR (Criminal) 1052; Gian Singh 2012 (4) RCR (Criminal) 543; CJM SAS Nagar verification report dated 01.12.2025; CRM-M-64034-2025; petition allowed; FIR and consequential proceedings quashed qua petitioners.

What did the court decide?

Quashing of FIR No.218 dated 13.08.2025, registered under Sections 126(2), 115(2), 351(2), 324(4), 191(3) and 190 of BNS, 2023 at Police Station Phase-1, District SAS Nagar, Mohali, and all other consequential proceedings arising therefrom, qua the petitioners, on the basis of the compromise. ¶15

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

What the court decided

AI extract

Outcome

¶15

Issue for consideration

Whether FIR No.218 dated 13.08.2025, registered under Sections 126(2), 115(2), 351(2), 324(4), 191(3) and 190 of BNS, 2023 at Police Station Phase-1, District SAS Nagar, Mohali, and all subsequent proceedings arising therefrom, should be quashed on the basis of the compromise between the parties. +1 more

¶1

Court's answer

Perusing the report of the trial Court regarding the amicable settlement between the petitioner and the complainant, the Court found that quashing the FIR will accord a quietus to all disputes between the parties, that no useful purpose would be served in continuing the proceedings, and that, in order to secure the ends of justice, the criminal proceedings in the present case deserve to be quashed.

¶14

Ratio / Principle

Proceeding on the report of the Chief Judicial Magistrate, the Court acted on the footing that the compromise is genuine and without undue influence or coercion, that there are seven accused, none of whom has been declared a proclaimed offender and none of whom is involved in any other FIR.

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Key takeaways

The present petition is allowed.ratio¶15
FIR No.218 dated 13.08.2025 (registered under Sections 126(2), 115(2), 351(2), 324(4), 191(3) and 190 of BNS, 2023 at Police Station Phase-1, District SAS Nagar, Mohali) and all other consequential proceedings arising therefrom are quashed qua the petitioners on the basis of the compromise.ratio¶15

Detailed headnote1 paragraphs

Criminal Miscellaneous petition (CRM-M-64034-2025) allowed; FIR quashed on compromise. FIR No.218 dated 13.08.2025, registered under Sections 126(2), 115(2), 351(2), 324(4), 191(3) and 190 of BNS, 2023 at Police Station Phase-1, District SAS Nagar, Mohali, and all consequential proceedings arising therefrom were quashed qua the petitioners. Acting on the report dated 01.12.2025 of the Chief Judicial Magistrate, SAS Nagar (statements recorded; compromise genuine, without undue influence or coercion; seven accused; none a proclaimed offender and none involved in any other FIR), and invoking the inherent power under Section 482 Cr.P.C. recognised in Kulwinder Singh and others v. State of Punjab, 2007 (3) RCR (Criminal) 1052 (Full Bench) and Gian Singh v. State of Punjab and another, 2012 (4) RCR (Criminal) 543, the Court held that continued proceedings would serve no useful purpose, that quashing would accord a quietus to all disputes, and that quashing was required to secure the ends of justice.

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1. The present petition has be e n filed for quashing of F IR No.218, d a ted 13.08.2025, registered u n der Sections 126(2), 115(2), 351(2), 32 4 (4), 191(3) and 190 of BNS, 2 0 23, at Police Station Phase-1, District S A S Nagar, Mohali and all s u bsequent proceedings arising therefrom o n the basis of the compromise.

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This Court while issuing noti c e of motion vide order dated 14.11.2025 , directed the parties to appea r before the trial Court/Illaqa Magistrate f or recording their statements w i th regard to the compromise. 3. Pursuant to the aforesaid ord e r, report dated 01.12.2025 has

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been recei v ed from the Chief Judicial Ma g istrate, SAS Nagr, Mohali. A perusal of t h e said report reveals that state m ents of the concerned persons

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PARVEEN KUMAR 2026.01.23 17:14 I attest to the accuracy and integrity of this order/judgment.

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CRM-M-64034-2025 -2-

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have been recorded in the present case, who have stated that the matter has been settled between them and they have no objection in case the FIR in question is quashed. The compromise effected between them is genuine, without any undue influence and coercion. It is stated in the report that there are seven accused. None of the accused has been declared as proclaimed offender and is not involved in any other FIR.

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Heard learned counsel for the parties and also gone through the case file. 5. 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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PARVEEN KUMAR 2026.01.23 17:14 I attest to the accuracy and integrity of this order/judgment.

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CRM-M-64034-2025 -3-

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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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7. 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 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.

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8. Resultantly, the present petition is allowed and FIR No.218, dated 13.08.2025, registered under Sections 126(2), 115(2), 351(2), 324(4), 191(3) and 190 of BNS, 2023, at Police Station Phase-1, District SAS Nagar, Mohali and all other consequential proceedings arising therefrom are quashed qua the petitioners on the basis of the compromise.

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PARVEEN KUMAR 2026.01.23 17:14 I attest to the accuracy and integrity of this order/judgment.

Vishal Mittal and Others v. State of Punjab and Another

Case brief

What is this about?

What did the court decide?

Vishal Mittal and Others v. State of Punjab and Another

Case brief

What is this about?

What did the court decide?

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What the court decided

Issues for consideration

Cases cited

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