A workplace harassment FIR may be quashed after settlement where the complainant no longer supports prosecution.

Respondent No. 2 was employed as a counsellor at an educational institute from September 2022 to July 2023.

She alleged inappropriate conduct and unjustified penalisation by petitioner No. 1, her immediate superior, and inaction on her complaints and withholding of her dues by petitioner No. 2, the institute’s founder

The allegations led to FIR No. 120/2023 at P.S. Connaught Place under Sections 354A and 509 IPC

The parties later executed a settlement agreement dated 4 February 2025.

Respondent No. 2 appeared virtually, stated that she had accepted the petitioners’ apology, wished to move past the incident, and did not wish to pursue the complaint

The petitioners sought quashing of the FIR and consequential proceedings under Section 528 BNSS

Whether the High Court should exercise its inherent jurisdiction under Section 528 BNSS to quash the FIR and consequential proceedings in light of the parties’ settlement and respondent No. 2’s decision not to pursue the complaint

Whether quashing was appropriate given that the allegations concerned workplace harassment, notwithstanding the settlement and the related employment disputes

Section 528 BNSS provides for the High Court’s inherent jurisdiction to make orders necessary to secure the ends of justice or prevent abuse of the process of a court

Under Gian Singh v. State of Punjab, (2012) 10 SCC 303, the High Court may quash proceedings following a settlement where, having regard to the nature and gravity of the offence, the dispute is predominantly private or personal, the prospect of conviction is remote, and continuation would cause oppression or injustice; heinous and serious offences generally cannot be quashed merely on settlement

The Court also referred to Kapil Gupta v. State (NCT of Delhi), (2022) 15 SCC 44, concerning the significance of the complainant’s non-support of the prosecution and the stage of the trial

and to Karan Moolchandani v. State of NCT of Delhi, CRL.M.C. 5159/2025 (decided 1 August 2025), which quashed proceedings arising from workplace-harassment allegations under Sections 354A, 354D and 509 IPC after the parties resolved their dispute

The Court acknowledged that allegations of workplace harassment must not be taken lightly, but noted that, in this case, they arose in the course of employment and involved disputes concerning salaries and dues, which had been resolved

Respondent No. 2 had accepted the apology and unequivocally stated that she did not wish to pursue the complaint; the trial had also not commenced

Applying the settlement principles in Gian Singh and the authorities cited, the Court concluded that continuation of the proceedings would serve no useful purpose in the circumstances

It directed the petitioners to pay costs of ₹25,000 to the Delhi High Court Legal Services Committee within four weeks and file proof of payment with the Registry.