High Courts may quash non-compoundable personal-injury proceedings after voluntary settlement where public interest is unaffected.

FIR No. 0255/2025 was registered at P.S. Kashmere Gate under Sections 110, 126(2), 61(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023, following respondent no. 2’s allegation that individuals acting on the petitioner’s behalf assaulted and threatened him in a dispute concerning a parking contract

The parties later entered into a written settlement, effective from 18 July 2026, and sought quashing of the FIR

Respondent no. 2 confirmed in Court that the settlement was voluntary and that he did not wish to pursue the case; the State did not oppose the petition

1. Whether the High Court could quash the FIR and consequential proceedings under Section 528 of the BNSS on the basis of a voluntary settlement, although the alleged offence under Section 110 BNS was non-compoundable

2. Whether, in the circumstances of this case, continuing the criminal proceedings would serve a meaningful purpose or be contrary to the interests of justice

Section 528 of the BNSS preserves the High Court’s inherent power to make orders necessary to secure the ends of justice or prevent abuse of the process of any court; that power is distinct from statutory compounding and may extend to non-compoundable offences in appropriate cases

Relying on Gian Singh v. State of Punjab, (2012) 10 SCC 303, the Court noted that proceedings may be quashed where the dispute is predominantly private, settlement makes conviction unlikely, and continuation would defeat the ends of justice, while serious offences affecting society ordinarily cannot be quashed merely on compromise

It also applied Narinder Singh v. State of Punjab, (2014) 6 SCC 466, which requires cautious exercise of the power, consideration of the nature and gravity of the offence, and assessment of the prospects of conviction and the impact of continuing proceedings

Deepak Kumar v. State (Govt. of NCT) of Delhi, 2024 SCC OnLine Del 1305, was cited for the principle that the decision depends on the circumstances of each case, including the offence’s gravity and societal impact

The Court treated the dispute as personal in nature, arising from the parties’ conflict over a parking contract, and noted that the alleged injury-related dispute had been resolved through a voluntary settlement confirmed by respondent no. 2 in Court

Although Section 110 BNS was non-compoundable, the Court considered that the matter did not involve a loss or damage to the public at large and found no useful purpose in continuing the proceedings after settlement

Applying the cited authorities, it concluded that quashing in these circumstances would serve the interests of justice

The Court quashed FIR No. 0255/2025, registered under Sections 110, 126(2), 61(2) and 3(5) BNS, together with all proceedings arising from it

The parties were directed to remain bound by the Memorandum of Settlement Deed dated 10 August 2026, and the pending application was disposed of