Quashing of Section 307 BNS proceedings permissible for matrimonial or family disputes despite nature of injuries.

The case involves two cross-FIRs arising from a dispute between two branches of an extended family related through matrimonial alliances

FIR No. 300/2025 was registered under Section 79 of the BNS and Section 67 of the IT Act regarding the alleged circulation of intimate photographs of the complainant

FIR No. 204/2025 was subsequently registered under Sections 109, 110, and 3(5) of the BNS (corresponding to Section 307 IPC—Attempt to Murder) following a physical altercation during a family panchayat meeting intended to resolve the initial dispute

The complainant in the second FIR sustained a head injury requiring stitches

During the pendency of the proceedings, the parties executed two Memoranda of Understanding on 28.07.2025, amicably resolving all disputes and seeking quashing of the criminal proceedings

Whether the High Court, in exercise of its inherent powers under Section 528 of the BNSS (Section 482 CrPC), can quash criminal proceedings involving non-compoundable and serious offences like Section 109 BNS (Attempt to Murder) based on a private settlement

Whether the continuation of the cross-proceedings would serve the ends of justice or result in an exercise in futility given the familial nature of the dispute and the settlement reached

The Court primarily applied Section 528 of the BNSS (Section 482 CrPC), which preserves the High Court's inherent power to prevent abuse of process or secure the ends of justice

It relied on the landmark principles in Gian Singh v. State of Punjab, establishing that while serious crimes against society cannot be quashed via settlement, disputes of a matrimonial or family nature may be quashed if the possibility of conviction is remote

The Court further applied the specific guidelines for Section 307 IPC cases 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 if the injury is not from a lethal weapon, the settlement is reached early (during investigation/infancy), and it promotes familial harmony

The Court observed that the disputes were rooted in personal and familial discord between members of an extended family where matrimonial alliances remain intact

Regarding the attempt to murder charge, the Court noted that the incident occurred during a sudden altercation without sharp-edged weapons or firearms, and the complainant had recovered without lasting consequences

Applying the Narinder Singh factors, the Court found that the settlement was reached promptly (within months of the FIR), during the investigation stage, and that the possibility of conviction was "remote and bleak" because the complainants no longer wished to support the prosecution

The Court reasoned that quashing the FIRs was necessary to restore peace and harmony between the related parties, as continuing the trial would be an exercise in futility

The Court allowed the petitions, quashing FIR No. 300/2025 (P.S. Shahbad Dairy) and FIR No. 204/2025 (P.S. Paschim Vihar) along with all consequential proceedings

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