Facts
The deceased, Atal Bihari Parmar, was employed by the petitioner at M/s R.R. Metal. He allegedly suffered electrocution while working at the premises and later died; an FIR was registered against the petitioner under Sections 106(1) and 289 of the Bharatiya Nyaya Sanhita, 2023 (BNS).
Source reference: p.2, para. 4The deceased’s family pursued a claim before the Deputy Labour Commissioner. The parties later entered into a Memorandum of Understanding dated 10 August 2026, under which the petitioner agreed to pay ₹10 lakh as full and final compensation.
Source reference: p.2, para. 5The deceased’s wife, appearing for herself and the minor children, and the deceased’s parents confirmed the settlement and stated that they had no objection to quashing the FIR; the State also raised no objection.
Source reference: p.3, paras. 6–8The petitioner sought quashing of the FIR and consequential proceedings under Article 226 of the Constitution and Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS).
Source reference: p.1, para. 3Issues
1. Whether the FIR and consequential proceedings under Sections 106(1) and 289 BNS could be quashed on the basis of the parties’ settlement.
Source reference: p.1, para. 3; p.3, paras. 7–102. Whether quashing the proceedings in the circumstances would serve the interests of justice.
Source reference: p.3, para. 9; p.4, para. 10Law Applied
Article 226 of the Constitution and Section 528 BNSS were invoked as the bases for the High Court’s quashing jurisdiction.
Source reference: p.1, para. 3Relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303, the Court noted that the High Court may quash criminal proceedings after a settlement where continuing them would be unfair, contrary to the interests of justice, or an abuse of process, and where ending them would secure the ends of justice.
Source reference: p.3, para. 9The FIR alleged offences under Sections 106(1) and 289 BNS.
Source reference: p.2, para. 4Reasoning
The Court accepted that the parties had amicably settled the dispute, that the settlement was voluntary and free from coercion, and that the deceased’s family had no objection to quashing the FIR.
Source reference: p.3, paras. 7, 10The State likewise did not oppose the petition.
Source reference: p.3, para. 8Applying the Gian Singh principles, the Court concluded that, in these circumstances, continuing the criminal proceedings would not serve the interests of justice.
Source reference: p.3, para. 9; p.4, para. 10Holding
The Court allowed the petition and quashed FIR No. 0018/2026, dated 21 January 2026, registered at P.S. GTB Enclave under Sections 106(1) and 289 BNS, together with all consequential proceedings.
Pending applications were also disposed of.
Source reference: p.4, para. 13Acts & Sections Cited
3 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.
Bharatiya Nagarik Suraksha Sanhita, 20231
Bharatiya Nyaya Sanhita, 20232
Original Court PDF
Sh. Arpit JainvsThe State Govt. Of Nct Of Delhi And Ors.
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