Alleged Bullet Pierced Labourer’s Saree And Wounded Her; MP HC Refuses To Quash FIR Despite Compromise

The petitioners sought to quash, under Section 528 of the BNSS, FIR Crime No. 343/2023 registered at Police Station Sirol, Gwalior, for offences under Sections 308, 294 and 34 of the IPC, together with consequential proceedings.

The prosecution alleged that during a firing incident, a bullet pierced the complainant’s saree and injured her below the navel.

The parties later entered into a compromise, which the Principal Registrar verified as voluntary and free from coercion.

The complainant supported the petitioners’ request for quashing.

Section 528 of the BNSS confers inherent jurisdiction to quash criminal proceedings, but that jurisdiction is not ordinarily exercised merely because the parties have settled where the allegations disclose a serious offence affecting society at large.

Relying on State of Madhya Pradesh v. Laxmi Narayan, (2019) 5 SCC 688, the Court stated that serious offences such as attempt to murder should not ordinarily be quashed on settlement alone and that the Court must examine whether the relevant allegation is supported by the evidence and circumstances.

The Court also relied on Vijay Kumar Kela & Anr. v. Central Bureau of Investigation & Anr., 2026 INSC 588, for the principle that heinous or serious offences with a societal impact should not be quashed merely because the victim or parties have settled, given the public interest in prosecution.

The Court considered that the allegations at this stage involved the use of a firearm and firing allegedly intended to cause death, resulting in injury to the complainant.

It held that the alleged occurrence was not overwhelmingly private or civil in character and that the later compromise did not remove either the seriousness of the allegations or the public interest in prosecution.

The verified, voluntary nature of the settlement therefore did not provide sufficient grounds to exercise the inherent jurisdiction to quash the proceedings.

I.A. Nos. 7872/2026 and 7873/2026 were disposed of, and the Court clarified that its observations would not prejudice either party before the Trial Court.