Delhi High Court

Quashing of Cross-FIRs Under Inherent Powers Following Amicable Settlement and Voluntary Withdrawal of Allegations

Sunil Goel vs The State (Nct Of Delhi) And Ors

Delhi High CourtJUDGMENT: April 27, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The dispute arose from an incident on 23.11.2023 at Venkateshwar School, Dwarka, involving two brothers, Sunil Goel and Mahavir Goel (the School Chairman).

Source reference: para. 2–4

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

Source reference: para. 3, 5

Consequently, cross-FIRs were registered at P.S. Dwarka South: FIR No. 564/2023 (under Section 509/427 IPC) against Sunil Goel, and FIR No. 567/2023 (under Sections 325/341/506/34 IPC) against Mahavir and Abhishek Goel.

Source reference: para. 5, 13

Subsequently, the parties settled all disputes amicably via Memoranda of Understanding (MoU) dated 20.04.2026 and sought quashing of the proceedings.

Source reference: para. 6–7
02

Issues

1. Whether the High Court should exercise its inherent powers to quash criminal proceedings in cross-FIRs involving non-compoundable offences when the parties have reached an amicable settlement.

Source reference: para. 11–12
03

Law Applied

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.

Source reference: para. 12

Indian Penal Code (IPC) provisions under which the FIRs were registered, including Sections 509 (insulting modesty), 427 (mischief), 325 (grievous hurt), 341 (wrongful restraint), and 506 (criminal intimidation).

Source reference: para. 13
04

Reasoning

The Court observed that the parties, who are close relatives (real brothers), had settled their disputes voluntarily without coercion.

Source reference: para. 4, 10

A review of the Compromise Deeds revealed that the incident stemmed from a misunderstanding and that all parties had undertaken to withdraw all allegations and counter-allegations unconditionally.

Source reference: para. 7

The Court noted that the complainants in both FIRs were present, duly identified, and expressed "no objection" to the quashing.

Source reference: para. 9–10

The Court reasoned that since the parties no longer wished to press charges, continuing the criminal proceedings would serve no useful purpose and would be a futile exercise.

Source reference: para. 11
05

Holding

The Court answered the issue in the affirmative, holding that quashing the FIRs was necessary to secure the ends of justice.

The Court quashed FIR No. 564/2023 and FIR No. 567/2023, along with all consequential proceedings.

Source reference: para. 13

The parties were directed to submit the original MoUs and affidavits before the Trial Court within four weeks to be made part of the official record.

Source reference: para. 13

The petitions were disposed of accordingly.

Source reference: para. 14
Delhi High Court

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Sunil GoelvsThe State (Nct Of Delhi) And Ors

Delhi High Court · April 27, 2026

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