Facts
On November 17, 2019, Dhanpat Dass, a chowkidar, died after being trapped in an unauthorized goods lift at a factory premises in Mayapuri Phase-2.
Source reference: p. 1-2FIR No. 0253/2019 was registered under Sections 287/304A of the IPC against the factory owners based on allegations of negligent upkeep of the lift.
Source reference: p. 1Charges were subsequently framed against all petitioners.
Source reference: p. 2During the proceedings, the petitioners entered into a Memorandum of Understanding (MoU) with the legal representatives (LRs) of the deceased, paying a total compensation of ₹3,10,000.
Source reference: p. 2The LRs, represented by the deceased’s son, Ram Sogarathdass, expressed their desire to settle the matter and filed a "no objection" for quashing the FIR.
Source reference: p. 2-3Issues
1. Whether the High Court should exercise its inherent power to quash the FIR and consequential proceedings for offences under Sections 287/304A IPC on the basis of a settlement between the accused and the victim's legal heirs.
Source reference: p. 1, 52. Whether the lack of an eyewitness and the reliance on mere ownership of the property constitute sufficient grounds to sustain a conviction for gross negligence.
Source reference: p. 3-4Law Applied
The Court primarily applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 CrPC), regarding inherent powers to quash proceedings to prevent abuse of process.
Source reference: p. 5It relied on Gian Singh v. State of Punjab, which permits quashing based on settlement except for heinous offences like rape or murder.
Source reference: p. 5The Court further applied the requirement of "gross negligence" and "culpable negligence" under Sections 287 and 304A IPC, citing Babu Khan v. State.
Source reference: p. 4Precedents like Sunil Malhotra v. State and Bhanwar Singh v. State were invoked to support quashing FIRs under Section 304A when incidents are accidental and parties have settled.
Source reference: p. 4Reasoning
The Court reasoned that to sustain a conviction under Sections 287/304A IPC, the prosecution must prove "wanton disregard" or "gross negligence," which was not established here as the factory owners were charged merely based on property ownership rather than specific acts of omission.
Source reference: p. 4The Court noted that the solitary public witness (the son of the deceased) was no longer supporting the prosecution, describing the event as a "mere accident," thus making the chances of conviction "very bleak".
Source reference: p. 3-4Justice Jain observed that continuing the trial would serve no purpose as the LRs had been compensated and were uninterested in pursuing the case.
Source reference: p. 3, 5The court emphasized that Section 304A does not involve mens rea or intentional harm, placing it outside the category of "heinous crimes" that cannot be settled.
Source reference: p. 5Holding
The Court answered that quashing was appropriate to secure the ends of justice as the settlement was voluntary and the evidence of negligence was insufficient.
The High Court allowed the petition and quashed FIR No. 0253/2019 and all consequential proceedings.
Source reference: p. 5The holding was made subject to the petitioners paying an additional compensation of ₹1,00,000 to the legal heirs on the next trial court date (June 9, 2026), bringing the total settlement to ₹4,10,000.
Source reference: p. 5Original Court PDF
Neeraj Bhalla & Ors.vsState Govt. Of Nct Of Delhi And Anr.
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