Ishpal Singh and Anr v. State (Nct of Delhi)

O R D E R %

31.08.2026

¶1The petitioners have preferred the present petition seeking quashing of FIR No. 115/2022, dated 24.01.2022, registered at Police Station Jagat Puri, District Shahdara, Delhi, for offences punishable under Sections 506/509/34 of the Indian Penal Code, 1860 ["IPC"], alongwith all consequential proceedings arising therefrom, on the basis of a settlement between the parties.

¶2Issue notice. Mr. Hitesh Vali, learned Additional Public Prosecutor, accepts notice on behalf of the State. Respondent No. 2 – complainant, appears in person, and accepts notice. She does not seek the assistance of counsel, including Legal Aid counsel.

¶3The petitioners are present before the Court and have been duly identified by their learned counsel as well as by the Investigating Officer ["IO"]. The complainant is also present in Court, and has been identified The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. by the IO.

¶4The subject FIR was registered at the instance of respondent No. 2, who alleged that the petitioners, who are her neighbours, used obscene language and made inappropriate gestures towards her. Upon completion of the investigation, a chargesheet was filed under Sections 354/506/509/34 of the IPC.

¶5Charges have been framed by the Mahila Court vide order dated

01.06.2024.

¶6During the pendency of the present proceedings, the parties have amicably resolved their disputes, as recorded in a Settlement Agreement/Compromise Deed executed on 04.05.2026. The settlement records that the FIR was lodged on account of a misunderstanding and certain personal disputes between the parties.

¶7Although the settlement does not contemplate any monetary consideration, respondent No. 2, who is present in Court, states that she is satisfied with the terms thereof. She further submits that the allegations, including those under Section 354 of the IPC, arose in the backdrop of a misunderstanding and that she does not wish to pursue the matter further.

¶8The parties have also confirmed that the settlement was entered into voluntarily, and without any coercion or undue influence.

¶9In light of the aforesaid, the parties seek quashing of the impugned FIR.

¶10Even in cases involving non-compoundable offences, the Supreme Court has consistently held that, in appropriate cases, the High Court may exercise its inherent jurisdiction to quash an FIR and the proceedings arising therefrom on the basis of a settlement between the parties. In Gian The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. Singh v. State of Punjab and Anr.1, the Supreme Court held as follows: "58. Where the High Court quashes a criminal proceeding having regard to the fact that the dispute between the offender and the victim has been settled although the offences are not compoundable, it does so as in its opinion, continuation of criminal proceedings will be an exercise in futility and justice in the case demands that the dispute between the parties is put to an end and peace is restored; securing the ends of justice being the ultimate guiding factor. No doubt, crimes are acts which have harmful effect on the public and consist in wrongdoing that seriously endangers and threatens the well-being of the society and it is not safe to leave the crime-doer only because he and the victim have settled the dispute amicably or that the victim has been paid compensation, yet certain crimes have been made compoundable in law, with or without the permission of the court. In respect of serious offences like murder, rape, dacoity, etc., or other offences of mental depravity under IPC or offences of moral turpitude under special statutes, like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity, the settlement between the offender and the victim can have no legal sanction at all. However, certain offences which overwhelmingly and predominantly bear civil flavour having arisen out of civil, mercantile, commercial, financial, partnership or such like transactions or the offences arising out of matrimony, particularly relating to dowry, etc. or the family dispute, where the wrong is basically to the victim and the offender and the victim have settled all disputes between them amicably, irrespective of the fact that such offences have not been made compoundable, the High Court may within the framework of its inherent power, quash the criminal proceeding or criminal complaint or FIR if it is satisfied that on the face of such settlement, there is hardly any likelihood of the offender being convicted and by not quashing the criminal proceedings, justice shall be casualty and ends of justice shall be defeated. The above list is illustrative and not exhaustive. Each case will depend on its own facts and no hard-and-fast category can be prescribed."2 Further, in Narinder Singh & Ors. v. State of Punjab & Anr.3, the Supreme Court has also laid down guidelines for High Courts while accepting settlement deeds between parties and quashing the proceedings. The relevant observations in the said decision read as under: 1 (2012) 10 SCC 303. 2 Emphasis supplied. 3 (2014) 6 SCC 466. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. "29. In view of the aforesaid discussion, we sum up and lay down the following principles by which the High Court would be guided in giving adequate treatment to the settlement between the parties and exercising its power under Section 482 of the Code while accepting the settlement and quashing the proceedings or refusing to accept the settlement with direction to continue with the criminal proceedings:

29.1. Power conferred under Section 482 of the Code is to be distinguished from the power which lies in the Court to compound the offences under Section 320 of the Code. No doubt, under Section 482 of the Code, the High Court has inherent power to quash the criminal proceedings even in those cases which are not compoundable, where the parties have settled the matter between themselves. However, this power is to be exercised sparingly and with caution.

29.2. When the parties have reached the settlement and on that basis petition for quashing the criminal proceedings is filed, the guiding factor in such cases would be to secure:

(i) ends of justice, or

(ii) to prevent abuse of the process of any court. While exercising the power the High Court is to form an opinion on either of the aforesaid two objectives.

29.3. Such a power is not to be exercised in those prosecutions which involve heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. Such offences are not private in nature and have a serious impact on society. Similarly, for the offences alleged to have been committed under special statute like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity are not to be quashed merely on the basis of compromise between the victim and the offender.

29.4. On the other hand, those criminal cases having overwhelmingly and predominantly civil character, particularly those arising out of commercial transactions or arising out of matrimonial relationship or family disputes should be quashed when the parties have resolved their entire disputes among themselves.

29.5. While exercising its powers, the High Court is to examine as to whether the possibility of conviction is remote and bleak and continuation of criminal cases would put the accused to great oppression and prejudice and extreme injustice would be caused to him by not quashing the criminal cases."4

¶11The present case stems from a dispute between neighbours, which 4 Emphasis supplied. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. has since been resolved amicably. Applying the principles laid down by the Supreme Court, respondent No. 2 has unequivocally stated before this Court that the settlement was entered into voluntarily. In these circumstances, I am of the view that the present case warrants the exercise of its inherent jurisdiction. The continuation of the criminal proceedings is also unlikely to culminate in a conviction and would amount to an empty formality, thereby unnecessarily burdening the judicial system and leading to the avoidable consumption of public resources.

¶12The petition is, accordingly, allowed, and FIR No. 115/2022, dated

24.01.2022, registered at Police Station Jagat Puri, District Shahdara, Delhi, alongwith all consequential proceedings arising therefrom, is hereby quashed, subject to payment of costs of Rs. 20,000/- to be paid by the petitioners collectively to the Delhi High Court Bar Association Costs Account [A/C No. 15530110179338; IFSC No. UCBA0001553; UCO Bank, Delhi High Court Branch] within a period of four weeks from today. An affidavit of compliance shall be filed within two weeks thereafter.

¶13The parties shall remain bound by the terms of the settlement.

¶14The petition is accordingly disposed of. PRATEEK JALAN, J AUGUST 31, 2026 SS/KA/ The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

* IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010406502026 + CRL.M.C. 6387/2026 ISHPAL SINGH AND ANR .....Petitioners Through: Mr. Tariz Jameel, Advocate with Petitioners. versus STATE (NCT OF DELHI) .....Respondent Through: Mr. Hitesh Vali, APP with WSI Sunita. Respondent No. 2 in person. CORAM: HON'BLE MR. JUSTICE PRATEEK JALAN