Investigating Officer must verify compromise validity and roles of non-settling co-accused before FIR quashing.

The petitioners filed three connected criminal miscellaneous petitions seeking to quash FIR Crime No. 19 of 2025, registered at Police Station Pandri, Raipur, for alleged offences under Sections 120-B (Criminal Conspiracy), 409 (Criminal breach of trust), and 420 (Cheating) of the IPC.

Petitioner Kapil Chandrakant Shelke (CRMP No. 2667 of 2025) claimed that a settlement agreement dated 15.10.2025 was executed with the complainant, Respondent No. 2, who had purportedly received the agreed amount.

The remaining petitioners, who are Directors of various companies, were not parties to the settlement.

During the hearing, counsel for Respondent No. 2 did not acknowledge or confirm the existence of the settlement.

1. Whether the impugned FIR and consequential proceedings should be quashed based on an unverified private settlement.

2. Whether the Investigating Officer should be directed to verify the authenticity of a compromise and the specific roles of multiple accused persons before the court proceeds with quashing.

The Court exercised its inherent power to oversee the quashing of criminal proceedings arising out of private or commercial disputes where a settlement is alleged.

It applied the principle that when a compromise is contested or unverified in court, the appropriate procedure is to direct the Investigating Officer or the trial court to authenticate the settlement.

The court also recognized that the roles of co-accused (such as company Directors) must be individually assessed even if one party has settled.

The Court noted that although a settlement agreement was presented by one petitioner, the complainant's counsel remained silent on its validity at the present stage.

Since the dispute involved multiple petitioners with varying degrees of involvement—specifically company Directors who were not signatories to the compromise—the Court found it necessary to ensure the settlement was bona fide and legally binding on all relevant parties.

Consequently, instead of quashing the FIR immediately, the Court determined that a verification report from the Investigation Officer was required to confirm the authenticity of the agreement and to clarify the roles of the remaining accused individuals who were not part of the compromise.

The I.O. was ordered to submit a report to the competent Court within four weeks, specifically considering the roles of the other petitioners/accused.

The Court further ordered that the interim protection granted to the petitioners would continue for four weeks and directed the Superintendent of Police, Raipur, to ensure compliance with these directions.