Section 307 IPC invocation does not bar quashing where the injury is simple and settlement is genuine.

The petitioners sought quashing of FIR No. 0338/2024, registered at P.S. Palam Village under Sections 307, 506 and 34 IPC and Section 27 of the Arms Act, on the basis of a settlement.

The FIR arose from a monetary dispute: it alleged that, during an altercation at respondent no. 2’s house, petitioner no. 1 called petitioner no. 2, who fired a firearm and injured respondent no. 3; it also alleged threats and property damage.

The investigation was complete and the charge-sheet and supplementary charge-sheet had been filed. The State’s status report described respondent no. 3’s injury as “simple blunt” and stated that the firearm was licensed.

The parties relied on a settlement deed dated 18 July 2024 and stated that the settlement was voluntary.

The respondents and petitioners appeared before the Court and confirmed their positions.

Whether the High Court should quash the FIR and consequential proceedings under its inherent jurisdiction despite the invocation of Section 307 IPC and Section 27 of the Arms Act, where the parties have settled?

Whether the injury, licensed status of the firearm, stage of the proceedings, and voluntary settlement supported exercising that jurisdiction in this case?

The Court relied on the inherent power under Section 482 CrPC/Section 528 BNSS to quash even non-compoundable criminal proceedings following settlement, while recognising that the power is discretionary and must be exercised sparingly to secure the ends of justice or prevent abuse of process (Gian Singh v. State of Punjab, (2012) 10 SCC 303).

Applying Narinder Singh v. State of Punjab, (2014) 6 SCC 466, the Court noted that, for a case invoking Section 307 IPC, the Court must assess the factual material—including the injury, weapon, prospects of conviction, nature of the dispute, and timing of settlement—rather than rely solely on the section’s inclusion in the FIR; the stage of proceedings is also relevant.

The Court also relied on Naushey Ali v. State of U.P., 2025 INSC 182, for the principle that invocation of Section 307 IPC alone does not bar settlement-based quashing and that the factual matrix must be examined.

The Court treated the MLC’s description of the injury as “simple blunt” and the firearm’s licensed status as relevant to assessing the gravity of the allegations and the likelihood of conviction, notwithstanding the FIR’s invocation of Section 307 IPC and Section 27 of the Arms Act.

It also relied on the parties’ voluntary settlement, their relationship as neighbours, the complainant’s and injured person’s stated unwillingness to pursue the matter, and the fact that the trial had yet to commence after the charge-sheets were filed.

In those circumstances, the Court found that continuing the proceedings would serve no useful purpose.

The quashing was conditional on petitioners nos. 1 to 4 each paying costs of Rs. 25,000 to Chintan Environmental Research and Action Group; a compliance report was directed to be filed with the Registry within four weeks.

The petition was disposed of.