Non-compoundable assault proceedings may be quashed on settlement where continuation would defeat justice.

FIR No. 121/2026 was registered at Police Station Mayapuri under Sections 118/3(5) of the Bharatiya Nyaya Sanhita, 2023 (“BNS”), following an altercation outside a café in which respondents 2 and 3 were stabbed and seriously injured

During the proceedings, the parties—who stated that they were friends—settled their dispute by a compromise deed dated 5 October 2026 and jointly sought quashing of the FIR

The State objected but indicated that it would be satisfied if costs were imposed

Whether the High Court could quash the FIR and consequential proceedings for a non-compoundable offence on the basis of the parties’ settlement.

Whether, in the circumstances of this case, quashing the proceedings would secure the ends of justice, and what consequential directions should be made.

The Court relied on Article 226 of the Constitution and Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”), under which the High Court may quash criminal proceedings to secure the ends of justice or prevent abuse of process, including in appropriate cases involving non-compoundable offences.

Gian Singh v. State of Punjab, (2012) 10 SCC 303, establishes that such power may be exercised where settlement makes continuation futile and quashing serves justice, while cautioning against quashing serious offences with substantial public impact.

Narinder Singh v. State of Punjab, (2014) 6 SCC 466, requires cautious, case-specific consideration, including the nature and gravity of the offence, the possibility of conviction, and whether continuation would cause injustice.

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

The Court accepted that the parties had resolved their dispute and, after interacting with them, noted their apologies and undertakings to conduct themselves appropriately in future.

It considered their young age, their friendship, their shared responsibility for the incident, and the settlement, and concluded that continuing the proceedings would be unfair and contrary to the interests of justice.

Although the allegations involved stabbing and serious injuries, the Court exercised its inherent power to quash the proceedings, subject to costs.

It directed petitioners 1 to 4 and respondent 2 to each pay ₹10,000 to the Delhi High Court Legal Services Committee within two weeks, and to file proof of payment with the Court and the Investigating Officer within the prescribed period.