Facts
Construction work was being carried out at a property in Sangam Vihar, Delhi, when Gauri Shankar, a worker, came into contact with a nearby transformer and died of electrocution.
Source reference: para. 2–3FIR No. 312/2025 was registered under Sections 290/106(1) of the Bharatiya Nyaya Sanhita, 2023, corresponding to Sections 288/304A IPC.
Source reference: para. 1At the time of the petition, the investigation was continuing and no charge-sheet had been filed.
Source reference: para. 4The petitioner sought quashing of the FIR on the basis of a comprehensive Settlement Deed dated 10 November 2025 executed with the legal representatives of the deceased worker.
Source reference: para. 5–9The widow received ₹2,50,000 under the settlement and, during the hearing, the petitioner additionally issued her a cheque for ₹50,000.
Source reference: para. 9, 12–14Issues
Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to quash the FIR concerning offences under Sections 290/106(1) BNS on the basis of an amicable settlement between the accused and the deceased’s legal representatives?
Source reference: para. 5, 15–16Whether, in view of the voluntary settlement, the consent of the informant and the deceased’s legal representatives, and the payment of compensation, continuation of the criminal proceedings would serve any useful purpose?
Source reference: para. 8–15Law Applied
The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which preserves the High Court’s inherent power to pass orders necessary to give effect to the BNSS, prevent abuse of the process of court, or secure the ends of justice.
Source reference: para. 15The Court exercised this power to quash the FIR despite the proceedings arising from offences corresponding to Sections 288/304A IPC, because the parties had voluntarily and comprehensively settled the dispute, the deceased’s legal representatives and the informant had no objection, and continuation of the prosecution would serve no useful purpose.
Source reference: para. 5–8, 12, 15–16Reasoning
The Court noted that the settlement was executed with the legal representatives of the deceased worker and that the widow had voluntarily confirmed the settlement, denied coercion or undue influence, and expressed no objection to quashing the FIR.
Source reference: para. 7–8, 12The informant likewise confirmed that he had no objection and had not suffered any injury in the incident.
Source reference: para. 9The Court also considered the verified particulars of the legal representatives and the petitioner’s financial capacity, as well as the payment of ₹2,50,000 and the additional cheque for ₹50,000.
Source reference: para. 10–14In these circumstances, the Court concluded that continuation of the criminal proceedings would not advance any useful purpose and that quashing the FIR would secure the ends of justice under Section 528 BNSS.
Source reference: para. 15Holding
The High Court allowed the petition and quashed FIR No. 312/2025 dated 16 July 2025, registered at Police Station Sangam Vihar, Delhi, under Sections 290/106(1) BNS, along with all consequential proceedings.
The Settlement Deed dated 10 November 2025 and the original affidavits were directed to be submitted to the concerned SHO/Investigating Officer within four weeks.
Source reference: para. 17The petition was accordingly disposed of.
Source reference: para. 18Acts & Sections Cited
4 provisions across 3 statutes referred to in this judgment. Each provision opens on LawLens.
Bharatiya Nyaya Sanhita, 20232
Indian Penal Code, 18601
Bharatiya Nagarik Suraksha Sanhita, 20231
Original Court PDF
Vikram SinghvsState Nct Of Delhi And Ors
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