Proceedings under Section 69 BNS quashed on settlement where relationship was consensual and voluntary

The Petitioner sought the quashing of FIR No. 148/2026, registered under Section 69 of the Bharatiya Nyaya Sanhita (BNS), 2023, following a complaint by Respondent No. 2.

The complainant alleged she was in a six-year relationship with the Petitioner, during which they engaged in a physical relationship based on his promise of marriage.

She claimed the Petitioner later reneged on this promise, citing a chronic autoimmune disorder (Immune Thrombocytopenia), while his family sought another match for him.

Subsequent to the FIR, the parties entered into a written settlement agreement on April 4, 2026.

During proceedings, the complainant stated the relationship was voluntary, consensual, and that the dispute was personal in nature.

Whether the High Court should exercise its inherent power to quash an FIR involving a non-compoundable offence under Section 69 of the BNS based on an amicable settlement between the parties?

The Court primarily applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (the successor to Section 482 of the Cr.P.C.), which preserves the High Court's inherent power to quash proceedings to prevent abuse of process or secure the ends of justice.

It relied on the precedent set in Narinder Singh Ors. vs. State of Punjab Anr. (2014), which held that non-compoundable cases can be quashed if the court is satisfied that the scope of conviction is remote and continuing proceedings serves no meaningful purpose.

The Court further referenced Madhukar Anr. vs. State of Maharashtra (2025) and related precedents to affirm that even offences of a sexual nature can be quashed when they arise from a consensual relationship and the parties have settled.

The Court observed that the complainant and her father appeared in person, confirming that the settlement was voluntary and intended to allow both parties to "move on".

The Court analyzed the nature of the relationship, noting the complainant’s admission that the six-year union was "healthy consensual" and voluntary.

By applying the Narinder Singh test, the Court reasoned that because the complainant no longer wished to support the prosecution, the likelihood of conviction was "remote and bleak".

The Court determined that the dispute was essentially personal and that maintaining the criminal proceedings would be a futile exercise of judicial resources and would not serve the interests of justice.

The Court quashed FIR No. 148/2026 and all consequential proceedings, subject to the Petitioner depositing costs of Rs. 25,000/- into the Delhi High Court Staff Welfare Fund within four weeks.

The Petitioner was also directed to submit the original settlement agreement and affidavits to the Investigating Officer.