Non-compoundable criminal proceedings may be quashed on settlement where conviction is remote and continuation serves no useful purpose.

The petitioner sought quashing of FIR No. 0297/2026 dated 9 June 2026, registered at Police Station Welcome under Sections 110/3(5) of the Bharatiya Nyaya Sanhita, 2023, corresponding to Sections 308/34 IPC, along with all consequential proceedings, on the basis of a settlement with respondent no. 2.

The FIR arose from respondent no. 2’s allegation that, while he and his friend were at Anup Vatika, the petitioner abused him and assaulted him on his head and face.

Investigation was pending and the charge-sheet had not yet been filed.

The parties executed a Compromise Deed dated 24 July 2026.

Respondent no. 2 appeared personally, confirmed the settlement, stated that it was voluntary and free from coercion, and expressed no objection to quashing the FIR.

The petitioner expressed remorse, undertook to bear the medical expenses relating to the injuries, and assured the Court that he would not engage in unlawful activity in the future.

Whether the High Court could exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to quash proceedings arising from alleged offences under Sections 110/3(5) BNS, corresponding to Sections 308/34 IPC, despite the offences being non-compoundable, on the basis of an amicable settlement.

Whether, in view of the voluntary settlement, the continuation of the criminal proceedings would serve any meaningful purpose when the likelihood of conviction was remote and bleak.

The Court exercised its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to prevent continuation of proceedings where the ends of justice so required.

Relying on Gian Singh v. State of Punjab & Anr., (2012) 10 SCC 303, the Court recognised that criminal proceedings involving private disputes may be quashed on the basis of a genuine settlement in appropriate cases.

Under Narinder Singh & Ors. v. State of Punjab & Anr., (2014) 6 SCC 466, even non-compoundable offences may be quashed where the Court is satisfied that continuation of the proceedings would serve no meaningful purpose and the possibility of conviction is remote and bleak.

The Court also relied on prior Delhi High Court decisions in which proceedings involving Section 308/34 IPC were quashed following amicable settlement.

The Court found that the dispute had been voluntarily and amicably resolved, as confirmed by respondent no. 2 in person after identification by the investigating officer.

There was no indication of coercion, undue influence, or pressure, and the petitioner expressed remorse and undertook to bear the relevant medical expenses.

Given that the matter remained at the investigation stage, the parties had settled their dispute, and respondent no. 2 had no objection to quashing, the Court concluded that continuing the prosecution would serve no useful purpose and that the prospects of conviction were remote and bleak.

Accordingly, the principles in Gian Singh and Narinder Singh justified exercise of the Court’s inherent jurisdiction notwithstanding the non-compoundable nature of the alleged offences.

The quashing was subject to the petitioner depositing costs of ₹20,000 with the Delhi High Court Legal Services Committee within four weeks.

The petitioner was further directed to submit proof of deposit, the original affidavits, and the Compromise Deed to the concerned Investigating Officer/SHO within an additional two weeks, and to bear any further prescribed medical expenses of respondent no. 2.

The petition and pending application were disposed of accordingly.