Amicable settlement of private property disputes justifies quashing cross-FIRs alleging cheating and forgery.

The petitions arose from cross-FIRs concerning a property bearing No. Q-66, Roop Nagar, Bhagat Enclave, Bindapur Extension, Uttam Nagar, New Delhi.

In CRL.M.C. 6154/2026, Sushila Devi and others sought quashing of FIR No. 498/2021, registered at P.S. Bindapur under Sections 420/465/468/471/34 IPC, on the basis of a settlement with the complainant, Gyarsi Lal.

Although Gyarsi Lal subsequently died on 7 January 2026, the mediation settlement had been executed by him during his lifetime on 18 December 2025.

His surviving legal representatives—Deepak, Anand and Pooja—appeared before the Court and consented to quashing of the FIR.

In CRL.M.C. 6169/2026, Mamta sought quashing of cross-FIR No. 663/2015, registered under Sections 420/467/468/471/506/34 IPC, in which she was the surviving accused and which was at the stage of consideration of charge.

The complainant, Sandeep Ahlawat, confirmed the settlement and stated that he had withdrawn the connected civil suit concerning the property.

The civil court recorded the withdrawal in terms of the settlement, directed refund of court fees and drew a compromise decree sheet.

The parties’ comprehensive mediation settlement was recorded by the Delhi Mediation Centre, Dwarka Courts, on 18 December 2025.

Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to quash FIR No. 498/2021 and the consequential proceedings on the basis of an amicable settlement in a private property dispute.

Whether FIR No. 663/2015 and the proceedings arising from it should similarly be quashed where the complainant has settled the dispute, withdrawn the connected civil suit and consented to quashing.

Whether continuation of the criminal proceedings would serve any useful purpose when all concerned parties have accepted the settlement and no public-interest element remains.

The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which preserves the High Court’s inherent powers to pass orders necessary to give effect to the statutory scheme, prevent abuse of the process of court and secure the ends of justice.

The Court further applied the principle that criminal proceedings arising from predominantly private or civil disputes may be quashed on the basis of a genuine and voluntary settlement where the complainant and other affected parties do not wish to pursue the allegations, continuation of prosecution would serve no useful purpose, and quashing would not adversely affect any overriding public interest.

The substantive allegations in the FIRs concerned offences under Sections 420, 465/467, 468, 471, 506 and 34 IPC.

The Court found that the dispute was essentially private and property-related, and that all connected matters had been amicably resolved through mediation.

In relation to FIR No. 498/2021, the settlement had been signed by the original complainant during his lifetime, and all his surviving legal representatives appeared and expressly stated that they had no objection to quashing.

In relation to FIR No. 663/2015, the complainant personally confirmed the settlement, had withdrawn the connected civil suit, and accepted the compromise decree.

Since the complainants no longer wished to press the allegations, the property dispute stood resolved, and no public-interest consideration was involved, the Court concluded that continuing either prosecution would be purposeless and would amount to an abuse of process.

The circumstances therefore justified exercise of the inherent jurisdiction under Section 528 BNSS.

The quashing was made subject to the petitioners depositing a cost of ₹10,000 in each respective case with the Delhi High Court Legal Services Committee within four weeks.

In FIR No. 663/2015, proof of deposit and the original affidavits were to be filed before the Trial Court; in FIR No. 498/2021, they were to be handed over to the SHO/Investigating Officer, as investigation was still pending.

Both petitions and the pending applications were accordingly disposed of.