01Facts
The petitions under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) sought quashing of three FIRs registered at P.S. Maurice Nagar following a clash between two groups of students near the University of Delhi’s North Campus on 18 February 2025.
pp. 2–3The FIRs alleged offences under Sections 118(1), 329(3), 351(3) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 (BNS), as applicable in each FIR.
pp. 2–3The parties entered into a settlement deed dated 30 April 2026 and jointly sought quashing.
p. 3, 8The Court noted that the FIRs did not allege grievous hurt, attempt to murder, an offence under the Arms Act, or another offence of mental depravity.
p. 3, 802Issues
i.Whether the High Court should exercise its inherent jurisdiction under Section 528 BNSS to quash the FIRs and consequential proceedings where the parties have settled the dispute.
p. 2, 13ii.Whether the nature of the alleged offences and the circumstances of the incident presented any impediment to quashing the FIRs on the basis of settlement.
pp. 3–4, 8–1003Law Applied
Section 528 BNSS, which is pari materia to Section 482 of the Code of Criminal Procedure, 1973, preserves the High Court’s inherent power to quash criminal proceedings to secure the ends of justice or prevent abuse of process.
p. 2Under Gian Singh v. State of Punjab, (2012) 10 SCC 303, that power may be exercised in appropriate cases involving non-compoundable offences where the nature of the dispute, the settlement, and the interests of justice warrant quashing; serious offences and offences having substantial societal impact ordinarily cannot be terminated merely by private settlement.
pp. 8–9Narinder Singh v. State of Punjab, (2014) 6 SCC 466, further directs the Court to consider the character and gravity of the offence, the likelihood of conviction, and whether continuation of proceedings would cause oppression or defeat the ends of justice.
pp. 9–10The Court also referred to Husan Bano v. State (Govt. of NCT) Delhi, Crl.M.C. 5021/2025 (order dated 28 January 2026), concerning the quashing of settled cross-FIRs arising from a student altercation.
p. 10Provisions in the judgment · 6 · Linked ones open on LawLens
Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528
Code of Criminal Procedure, 1973 Section 482
Bharatiya Nyaya Sanhita, 2023 Section 118Section 351Section 3Section 329
04Reasoning
The Court treated the FIRs as arising from a spontaneous, isolated clash between student groups and noted that the alleged offences did not include grievous hurt, attempt to murder, an Arms Act offence, or another offence of mental depravity.
pp. 3–4, 8The parties had settled the dispute and jointly requested that the proceedings end; the Court also took into account that some petitioners were students seeking to pursue their studies without the matter remaining unresolved.
pp. 3–8Applying the principles in Gian Singh and Narinder Singh, and noting the absence of an impediment in the circumstances, the Court concluded that quashing was appropriate.
pp. 8–1105Holding
The Court allowed the petitions and quashed FIR Nos. 35/2025, 33/2025 and 36/2025, together with all consequential proceedings, insofar as they concerned the petitioners.
pp. 10–11The order was expressly limited to those FIRs and did not extend to any other FIR or proceeding, or to any person who was not a party to the petitions.
p. 11Original Court PDF
Naveen Choudhary Alias Naveen DedhavsState Govt Of Nct Of Delhi And Anr
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