High Court Quashes Cross-FIRs for Non-Compoundable Private Disputes Based on Voluntary Amicable Settlement

The court dealt with two petitions seeking the quashing of cross-FIRs (No. 354/2012 and No. 355/2012) registered at P.S. Vasant Kunj South following a scuffle between relatives and neighbors on October 30, 2012.

In the first case, the accused were charged under Sections 452/323/34 IPC regarding a quarrel involving family members; in the second, the accused were charged under Sections 323/325/341/34 IPC for allegedly blocking a path and engaging in a physical scuffle.

Both cases reached the stage of prosecution evidence.

Subsequently, the parties, who are related to each other, voluntarily entered into a Compromise Deed dated May 14, 2026.

Whether the High Court should exercise its inherent powers to quash criminal proceedings in cross-cases involving non-compoundable offences based on a private, amicable settlement between related parties.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 482 of the CrPC), which vests the High Court with inherent powers to prevent abuse of the process of any court or to secure the ends of justice.

The principle that where a dispute is predominantly private in nature and the parties have reached a settlement, the continuation of criminal proceedings serves no useful purpose and would be a waste of judicial time.

The Court observed that the parties were related and had resolved their disputes through a written settlement without any coercion or influence.

The Investigating Officers verified the identities of the parties, and the complainants expressed their desire not to press charges.

The Court reasoned that since the matter was primarily private and did not involve any significant "public interest," the likelihood of conviction was remote given the settlement.

Consequently, the Court found it "appropriate to quash both the FIRs" to meet the ends of justice.

The Court quashed FIR No. 354/2012 (U/s 451/323/34 IPC) and FIR No. 355/2012 (U/s 323/341/34 IPC) and all consequential proceedings arising therefrom.

The parties were directed to submit the original Compromise Deed and affidavits to the Trial Court within two weeks, and both petitions were disposed of.