Quashing of cross-FIRs for non-compoundable offences permitted to restore harmony in interconnected matrimonial and family disputes.

Two cross-FIRs were registered between two branches of an extended family related through multiple matrimonial alliances

FIR No. 300/2025 (P.S. Shahbad Dairy) was filed under Section 79 BNS and Section 67 IT Act, alleging the circulation and public display of the complainant’s intimate photographs during a family panchayat

FIR No. 204/2025 (P.S. Paschim Vihar West) was filed under Sections 109, 110, and 3(5) BNS, alleging physical assault during the same panchayat meeting, resulting in a head injury to the complainant

During the pendency of the proceedings, the parties executed two Memoranda of Understanding (MoUs) dated 28.07.2025, amicably resolving all disputes and seeking quashing of the FIRs

1. Whether the High Court should exercise its inherent power under Section 528 of the BNSS (Section 482 CrPC) to quash criminal proceedings involving non-compoundable and serious offences, including Section 109 BNS (Section 307 IPC), based on a private settlement

2. Whether the continuation of criminal proceedings in a matrimonial/family dispute, where a settlement has been reached, would serve the ends of justice or constitute an exercise in futility

The Court primarily applied Section 528 of the BNSS regarding the inherent powers of the High Court to prevent abuse of process

It relied on the landmark principles in Gian Singh v. State of Punjab, which established that while serious crimes like murder or rape cannot be quashed via settlement, disputes that are matrimonial or familial in nature may be quashed if a conviction is unlikely and peace restoration is paramount

Further, it applied the guidelines from Narinder Singh v. State of Punjab, State of M.P. v. Laxmi Narayan, and Naushey Ali v. State of U.P., which permit quashing of Section 307 IPC (now Section 109 BNS) cases if the injury is not from a lethal weapon, the settlement is reached early in the investigation, and the dispute has a predominantly civil/familial character

The Court observed that the cross-FIRs originated from the same family discord and a sudden altercation during a panchayat meeting rather than premeditated criminal intent

Regarding the serious charge of attempted murder (Section 109 BNS), the Court noted the absence of sharp-edged weapons or firearms and the fact that the victim’s head injury had no lasting consequences

The Court emphasized that the parties are closely related and their matrimonial alliances remain intact; thus, continuing the trial would likely disturb existing family harmony

Since the settlement was reached voluntarily and early in the investigation (within months of the incident), the Court determined that the possibility of conviction was "remote and bleak" and that forcing the parties through a trial would be oppressive

The Court allowed the petitions and quashed FIR No. 300/2025 and FIR No. 204/2025 along with all consequential proceedings

Consequently, the associated bail applications (BAIL APPLN. 3605/2025, 3613/2025, and 3619/2025) were disposed of as infructuous