Gujarat High CourtCriminal LawCriminal Procedure and Evidence

Gujarat HC Quashes FIR Alleging Abetment Of Suicide And SC/ST Atrocities After Complainant Consents To Settlement

PARMAR LAGDHIRSINH SABARSINH (LACKYBHAI)v.STATE OF GUJARAT

Gujarat HC Quashes FIR Alleging Abetment Of Suicide And SC/ST Atrocities After Complainant Consents To Settlement. PARMAR LAGDHIRSINH SABARSINH (LACKYBHAI) vs STATE OF GUJARAT. Gujarat High Court. LawLens
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In brief

The question

Whether the FIR and consequential proceedings could be quashed in exercise of the High Court’s inherent jurisdiction on the basis of the parties’ settlement.

The court held

The Court allowed the petition and quashed FIR No. 11191024250374 of 2025 registered at Ramol Police Station, together with all consequential proceedings arising from it, insofar as they concerned the applicant.

It also directed

Rule was made absolute; direct service was permitted.

01Facts

The applicant sought quashing of FIR No. 11191024250374 of 2025, registered at Ramol Police Station, Ahmedabad, for alleged offences under Sections 108, 296(b) and 54 of the Bharatiya Nyaya Sanhita, 2023; Sections 40, 42(a) and 42(d) of the Gujarat Money-Lenders Act, 2011; and Section 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989.

¶ 1, 4, 7

The applicant submitted that the dispute had been amicably settled. The complainant appeared before the Court, confirmed the settlement by affidavit, and stated that he had no objection to quashing the FIR and consequential proceedings.

¶ 2, 5, 7

The State opposed the petition, citing the seriousness of the allegations.

¶ 6

02Issues

i.Whether the FIR and consequential proceedings could be quashed in exercise of the High Court’s inherent jurisdiction on the basis of the parties’ settlement.

¶ 1, 4–9

ii.Whether continuation of the criminal proceedings, despite the settlement and the complainant’s consent, would amount to an abuse of process of law.

¶ 8

03Law Applied

The applicant invoked Article 226 of the Constitution and Sections 482 of the Code of Criminal Procedure, 1973, and 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, as bases for quashing.

¶ 1

The Court relied on Gian Singh v. State of Punjab, Madan Mohan Abbot v. State of Punjab, Nikhil Merchant v. Central Bureau of Investigation, Manoj Sharma v. State, Narinder Singh v. State of Punjab and State of Haryana v. Bhajanlal in considering whether criminal proceedings could be quashed following settlement and to prevent abuse of process.

¶ 4, 8

Provisions in the judgment · 6 · Linked ones open on LawLens

Code of Criminal Procedure, 1973 Section 482

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528

Bharatiya Nyaya Sanhita, 2023 Section 108Section 296Section 54

Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 Section 3

04Reasoning

The Court accepted the complainant’s affidavit as confirming an amicable settlement and his voluntary consent to quashing; the complainant also stated that he no longer wished to pursue the FIR.

¶ 5, 7

Applying the cited authorities, the Court concluded that continuing the proceedings against the applicant would cause unnecessary harassment, that further trial would be futile, and that continuation would amount to an abuse of process.

¶ 8

Although the State opposed quashing on the basis of the seriousness of the allegations, the Court considered the settlement and complainant’s consent sufficient to grant relief.

¶ 6–9

05Holding

The Court allowed the petition and quashed FIR No. 11191024250374 of 2025 registered at Ramol Police Station, together with all consequential proceedings arising from it, insofar as they concerned the applicant.

¶ 9

Rule was made absolute; direct service was permitted.

¶ 10
Gujarat High Court

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PARMAR LAGDHIRSINH SABARSINH (LACKYBHAI)vsSTATE OF GUJARAT

Gujarat High Court · October 28, 2026

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