A Section 354 FIR may be quashed when a private-dispute misunderstanding is amicably settled.

The petitioner sought quashing of FIR No. 0183/2023, registered at Police Station Civil Lines under Sections 354 and 354A IPC, on the basis of a settlement agreement dated 23 May 2026.

The settlement recorded that the allegations arose from a misunderstanding; both parties filed affidavits stating that they had settled their disputes, and the complainant confirmed she did not wish to pursue the matter after the petitioner’s apology.

Whether the FIR and consequential proceedings under Sections 354 and 354A IPC could be quashed in view of the parties’ settlement.

Whether the nature of the allegations created an impediment to quashing despite the settlement.

The Court relied on Shiji v. Radhika, (2011) 10 SCC 705, and Gian Singh v. State of Punjab, (2012) 10 SCC 303, concerning the exercise of the High Court’s quashing jurisdiction where parties have settled their dispute. These authorities permit quashing in appropriate cases involving private disputes, while excluding offences that fall within the class the Supreme Court has placed beyond settlement.

The Court considered the allegations under Sections 354 and 354A IPC and held that, in the circumstances of this case, the allegation under Section 354 arose from an essentially private dispute and was not within that excluded class.

The Court noted that the settlement deed described the FIR allegations as stemming from a misunderstanding, and that both parties had affirmed their settlement.

The complainant also reiterated that position and stated that she did not wish to pursue the case. Applying Shiji and Gian Singh, the Court found no impediment to quashing, given the parties’ common position and the private nature attributed to the dispute.

The petition was disposed of accordingly.