Delhi High Court

Quashing of Cross-FIRs for Non-Compoundable and POCSO Offences Permitted to Maintain Neighborhood Harmony and Peace.

Manjeet Singh @ Rinku & Ors. vs The State Nct Of Delhi And Anr

Delhi High CourtJUDGMENT: April 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The court heard two cross-petitions seeking the quashing of cross-FIRs registered at P.S. Rohini

Source reference: para. 1, 10

FIR No. 502/2025 was lodged by "Survivor H" (a minor) alleging that neighbors entered her house, touched her inappropriately, and threw red chilli powder

Source reference: para. 2

The cross FIR No. 504/2025 was lodged by one L.M., alleging that the opposite party entered her house, used obscene words, touched her inappropriately, and assaulted her family

Source reference: para. 3

Both incidents arose from a heated argument over noise

Source reference: para. 2, 5

Charge-sheets were filed in both matters

Source reference: para. 7

During the proceedings, the parties executed a Memorandum of Understanding (MoU) dated 13.12.2025, stating they had amicably settled the dispute to maintain harmony in their neighborhood

Source reference: para. 5, 6
02

Issues

1. Whether the High Court, exercising its inherent powers, can quash criminal proceedings involving non-compoundable offenses (including Section 10 of the POCSO Act) based on a voluntary settlement between the parties

Source reference: para. 8, 9

2. Whether continuing the proceedings would serve any meaningful purpose given the remote possibility of conviction following the settlement

Source reference: para. 8
03

Law Applied

The court primarily relied on the principles governing the quashing of non-compoundable cases based on compromise established in Gian Singh v. State of Punjab Anr. (2012) 10 SCC 303

Source reference: para. 8

It further applied the test from Narinder Singh Ors. vs. State of Punjab Anr. (2014) 6 SCC 466, which permits quashing if the court is satisfied that the scope of conviction is "remote and bleak" and that quashing would meet the ends of justice

Source reference: para. 8

The court also considered the transition of the Indian Penal Code (IPC) to the Bharatiya Nyaya Sanhita (BNS)

Source reference: para. 10
04

Reasoning

The court observed that the dispute originated from "temperamental issues" and a heated argument between neighbors rather than deep-seated criminality

Source reference: para. 5

By examining the parties in person, the court confirmed that the settlement was voluntary and intended to ensure "peaceful living in the locality"

Source reference: para. 6

Applying the Narinder Singh precedent, the court reasoned that since the complainants no longer wished to pursue the charges, the likelihood of a successful prosecution was negligible

Source reference: para. 8, 9

The court determined that quashing the FIRs was necessary to secure the ends of justice and prevent further neighborhood disputes, as the primary objective of the settlement was the restoration of communal harmony

Source reference: para. 9, 10
05

Holding

The court answered the issues in the affirmative, holding that quashing was appropriate to ensure justice and neighborhood peace

Consequently, the Court quashed FIR No. 502/2025 (under Sections 74/75(2)/76 BNS and Section 10 POCSO Act) and FIR No. 504/2025 (under Sections 115(2)/126(2)/74/75/3(5) BNS), along with all consequential proceedings

Source reference: para. 10

The parties were directed to submit original affidavits to the Trial Court within four weeks

Source reference: para. 10
Delhi High Court

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Manjeet Singh @ Rinku & Ors.vsThe State Nct Of Delhi And Anr

Delhi High Court · April 24, 2026

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