Deceased Complainant’s Heirs Settle Dispute, Gujarat HC Quashes Section 306 IPC FIR Against Five Accused

In brief

The question

1. Whether the FIR alleging offences under Sections 306 and 114 IPC and the consequential proceedings should be quashed in light of the settlement between the petitioners and the deceased complainant’s legal representatives.

The court held

The Court allowed the application and quashed the FIR, C.R. No. 11191010230692 of 2023, registered with Madhavpura Police Station, Ahmedabad City, and all consequential proceedings arising from it, qua the petitioners.

01Facts

The petitioners sought quashing of an FIR registered with Madhavpura Police Station, Ahmedabad City, for offences under Sections 306 and 114 of the Indian Penal Code, together with the consequential proceedings in Sessions Case No. 236 of 2024.

¶ 2, 10

The original complainant died on 28 October 2025; his legal representatives filed an affidavit stating that the dispute had been amicably settled and that they had no objection to quashing the FIR and related proceedings.

¶ 7, 9

The legal representatives appeared before the Court and confirmed the settlement and their no-objection.

¶ 10

02Issues

i.1. Whether the FIR alleging offences under Sections 306 and 114 IPC and the consequential proceedings should be quashed in light of the settlement between the petitioners and the deceased complainant’s legal representatives.

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ii.2. Whether continuing the prosecution despite the settlement would serve a useful purpose or amount to an abuse of the process of law.

¶ 11

03Law Applied

The Court relied on Gian Singh v. State of Punjab, Madan Mohan Abbot v. State of Punjab, Nikhil Merchant v. CBI, Manoj Sharma v. State, Narinder Singh v. State of Punjab and State of Haryana v. Bhajan Lal.

¶ 6, 11

These authorities inform the High Court’s power to quash criminal proceedings to secure the ends of justice, including where the circumstances and settlement make continuation an abuse of process and no useful purpose would be served.

The offences alleged were under Sections 306 and 114 IPC.

¶ 10

The judgment does not expressly identify a statutory provision as the source of the quashing power.

Provisions in the judgment · 2 · Linked ones open on LawLens

Indian Penal Code, 1860 Section 306 Section 114

04Reasoning

The Court considered the legal representatives’ affidavit and their in-court confirmation that the dispute had been settled and that they had no objection to quashing the proceedings.

¶ 9–10

Applying the cited authorities to those circumstances, it concluded that continuation of the prosecution would amount to an abuse of process and would serve no fruitful purpose; quashing was therefore necessary to secure the ends of justice.

¶ 11