01Facts
The petitions under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 sought quashing of three FIRs arising from a clash between two groups of students near the University of Delhi’s North Campus on 18 February 2025.
p. 2The FIRs alleged offences under Sections 118(1), 329(3), 351(3) and 3(5) of the Bharatiya Nyaya Sanhita, 2023.
pp. 2–8The parties executed a settlement deed dated 30 April 2026 and jointly sought to end the proceedings.
pp. 2–8The Court recorded that the petitioners were identified by the Investigating Officer and that the settlement resolved a dispute said to have arisen from a misunderstanding
pp. 2–802Issues
i.1. Whether the High Court should exercise its inherent jurisdiction under Section 528 BNSS to quash the non-compoundable FIRs and consequential proceedings in light of the parties’ settlement
pp. 2, 8–11ii.2. Whether the nature of the alleged offences and the circumstances of the incident presented any impediment to quashing
pp. 8–1103Law Applied
Section 528 BNSS, pari materia to Section 482 of the Code of Criminal Procedure, 1973, preserves the High Court’s inherent power to quash proceedings to secure the ends of justice or prevent abuse of process
p. 2Under Gian Singh v. State of Punjab, (2012) 10 SCC 303, a settlement may justify quashing non-compoundable proceedings where the nature of the dispute and the circumstances make continuation futile and quashing serves justice; serious offences and offences with significant public impact ordinarily cannot be quashed merely on settlement
pp. 8–9Narinder Singh v. State of Punjab, (2014) 6 SCC 466, directs the Court to consider the ends of justice, the likelihood of conviction, and whether continuation would cause oppression or injustice
pp. 9–10The Court also referred to Husan Bano v. State (Govt. of NCT) Delhi, Crl.M.C. 5021/2025, concerning quashing 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 that the parties had settled, rather than from serious violence warranting continuation irrespective of the settlement.
p. 3, 8It noted that the allegations did not include grievous hurt, attempt to murder, an offence under the Arms Act, or another offence of mental depravity
p. 3, 8The parties’ settlement, the petitioners’ status as students, and their wish to resume their academic pursuits supported the conclusion that continuation was unnecessary; the Court found no impediment to quashing and relied on the settlement and the cited authorities
pp. 8–1105Holding
The Court allowed the petitions and quashed, qua the petitioners, FIR No. 35/2025 in CRL.M.C. 8280/2026, FIR No. 33/2025 in CRL.M.C. 8281/2026, and FIR No. 36/2025 in CRL.M.C. 7750/2026, together with all consequential proceedings arising from those FIRs
p. 11The order was confined to the specified FIRs and did not extend to any other FIR or proceeding, or to any person other than the parties to the petitions.
p. 11Original Court PDF
Naveen Choudhary And Ors.vsState Govt. Of Nct Of Delhi
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