HIGH COURT QUASHES ATTEMPT TO MURDER PROCEEDINGS AS COMPLAINANT DECLARED ACCUSED INNOCENT DURING TESTIMONY

The Petitioner sought the quashing of FIR No. 0256/2025 registered at P.S. R.K. Puram under Section 109(1) of the Bharatiya Nyaya Sanhita (BNS), 2023 (corresponding to Section 307 IPC).

The prosecution alleged that during a parking dispute on July 13, 2025, the Petitioner, an auto-mechanic, threw petrol on the Respondent No. 2's car windshield, causing burn injuries to the Respondent.

However, during trial, the Respondent (complainant) turned hostile, testifying that his injuries were accidental—caused by tripping over a container (tasla) of inflammable material while smoking—and that the Petitioner had no involvement.

A Memorandum of Understanding (MoU) was executed between the parties on July 13, 2026, to settle the matter amicably.

1. Whether the High Court should exercise its inherent power under Section 482 CrPC (Section 528 BNSS) to quash proceedings for a non-compoundable, serious offence under Section 307 IPC based on a compromise.

2. Whether the continuation of criminal proceedings is justified when the sole eye-witness/victim has denied the accused's complicity during sworn testimony.

The Court applied Section 482 of the CrPC and Section 528 of the BNSS regarding the inherent powers of the High Court.

It relied on the landmark principles in Gian Singh v. State of Punjab, which allow quashing of non-compoundable cases to prevent abuse of process or secure the ends of justice, provided the offence is not a heinous crime against society.

It further applied Narinder Singh v. State of Punjab, which established that while Section 307 IPC is generally serious, the Court may quash it if the evidence of conviction is "remote and bleak," the settlement occurs at an early stage of trial, or the injury did not target vital parts with clear intent.

Reliance was also placed on State of Madhya Pradesh v. Laxmi Narayan.

The Court observed that although the charge was under Section 307 IPC, the possibility of conviction was "remote and bleak" because the complainant had already been examined and had categorically exonerated the Petitioner.

The victim’s testimony attributed the incident to a pure accident (entangling with a tasla), which directly contradicted the FIR.

The Court noted that the settlement was voluntary and without consideration.

Applying the Narinder Singh framework, the Court reasoned that since the star witness had turned hostile and a settlement was reached, prolonging the trial would only cause "oppression and prejudice" to the Petitioner, who remained incarcerated despite the lack of incriminating evidence.

The High Court quashed FIR No. 0256/2025 and all consequential proceedings. The Court directed the Petitioner’s immediate release from jail, provided he was not required in any other case, and ordered the original settlement documents to be placed on the Trial Court Record.