Quashing of Cross-FIRs Under Inherent Powers Following Amicable Settlement and Voluntary Compromise Between Related Parties

The dispute arose from an incident on November 23, 2023, at Venkateshwar School, Dwarka, involving Sunil Goel and his brother Mahavir Goel (Chairman of the school).

Sunil Goel alleged poor food hygiene in the school canteen, leading to an altercation, while school staff alleged that Sunil Goel assaulted them and used inappropriate language.

Consequently, two cross-FIRs were registered at P.S. Dwarka South: FIR No. 564/2023 (against Sunil Goel) and FIR No. 567/2023 (against Mahavir and Abhishek Goel).

Subsequently, the parties, who are close relatives, entered into a Memorandum of Understanding (MoU) dated April 20, 2026, to settle all disputes amicably and withdraw all allegations.

1. Whether the High Court should exercise its inherent powers to quash criminal proceedings in non-compoundable cases based on a voluntary settlement between the parties.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which preserves the inherent powers of the High Court to prevent abuse of the process of any court or otherwise to secure the ends of justice.

The court also considered the nature of the offenses charged under the Indian Penal Code (IPC), specifically Sections 509 (insulting modesty) and 427 (mischief) in one FIR, and Sections 325 (grievous hurt), 341 (wrongful restraint), 506 (criminal intimidation), and 34 (common intention) in the other.

The Court observed that the parties are real brothers and the incident stemmed from a misunderstanding.

Upon personal examination, the Court verified that the complainants in both FIRs appeared in person and confirmed that the settlement was arrived at voluntarily without any coercion or undue influence.

The Court reasoned that since the parties had settled their disputes and the complainants no longer wished to press charges, continuing the criminal proceedings would serve no useful purpose and would be a futile exercise for the judicial machinery.

Consequently, the Court found it a fit case to exercise its inherent jurisdiction to "secure the ends of justice" and maintain familial harmony.

The Court quashed FIR No. 564/2023 and FIR No. 567/2023 registered at P.S. Dwarka South, along with all consequential proceedings arising therefrom.

The parties were directed to submit the original MoU and affidavits before the Trial Court within four weeks to complete the record.

Both petitions were disposed of accordingly.