Delhi High Court
Criminal LawCriminal Procedure and Evidence

A voluntary settlement can warrant quashing a private financial-dispute FIR despite no repayment.

Sh Parveen Garg & Anr. vs The State Govt Of Nct Of Delhi & Anr.

Delhi High CourtJUDGMENT: September 30, 20262 MIN READSOURCE JUDGMENT
A voluntary settlement can warrant quashing a private financial-dispute FIR despite no repayment.. Sh Parveen Garg & Anr. vs The State Govt Of Nct Of Delhi  & Anr.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners sought quashing of FIR No. 187/2025, registered at Police Station Mukherjee Nagar under Sections 420, 406 and 34 IPC, on the basis of a settlement with respondent no. 2 dated 15 June 2026

Source reference: p. 2, para. 5–6

The complainant appeared in person, confirmed that he understood and voluntarily accepted the settlement, and acknowledged that it provided for no repayment and that he had relinquished his monetary claim concerning the transactions

Source reference: p. 4, para. 7

He stated that the petitioners lacked the financial means to pay any amount or compensation

Source reference: p. 4, para. 9

The Court first allowed an application under Section 528 BNSS to restore the petition, then considered the quashing petition on the same day

Source reference: p. 1, paras. 1–4
02

Issues

1. Whether the FIR and consequential proceedings should be quashed in light of the parties’ amicable settlement concerning private financial dealings

Source reference: p. 2, para. 5; p. 4, paras. 8–10

2. Whether the absence of repayment or compensation under the settlement prevented the Court from quashing the proceedings

Source reference: p. 4, paras. 7–10
03

Law Applied

Section 528 BNSS was invoked for restoration of the petition, which the Court allowed

Source reference: p. 1, paras. 1–3

For quashing, the Court relied on Gian Singh v. State of Punjab, (2012) 10 SCC 303, and Narinder Singh v. State of Punjab, (2014) 6 SCC 466, as authorities supporting the quashing of criminal proceedings in appropriate cases involving settlement of disputes between private parties

Source reference: p. 4, para. 10

The Court considered the private nature of the dispute and the complainant’s voluntary decision to relinquish his monetary claim relevant to its determination

Source reference: p. 4, paras. 7–9
04

Reasoning

The Court treated the dispute as concerning financial dealings between private persons, with no public funds involved

Source reference: p. 4, para. 8

The complainant confirmed that his decision to settle was voluntary and that he knowingly relinquished his monetary claim, despite there being no provision for repayment or compensation

Source reference: p. 4, paras. 7, 9

In light of those circumstances and the cited precedents, the Court found no impediment to quashing the proceedings

Source reference: p. 4, para. 10
05

Holding

The Court allowed the restoration application and restored CRL.M.C. 6040/2026 to its original number

It then quashed FIR No. 187/2025 under Sections 420, 406 and 34 IPC, along with all consequential proceedings, and disposed of the petition

Source reference: p. 5, paras. 11–12
06

Acts & Sections Cited

4 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Indian Penal Code, 18603

Delhi High Court

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Sh Parveen Garg & Anr.vsThe State Govt Of Nct Of Delhi & Anr.

Delhi High Court · September 30, 2026

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