Delhi High Court
Criminal LawCriminal Procedure and Evidence

Section 307 proceedings may be quashed on settlement where injuries are minor and conviction prospects remote.

Sanjay @ Sanju vs State Nct Of Delhi And Anr.

Delhi High CourtJUDGMENT: October 13, 20262 MIN READSOURCE JUDGMENT
Section 307 proceedings may be quashed on settlement where injuries are minor and conviction prospects remote.. Sanjay @ Sanju vs State Nct Of Delhi And Anr.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitions arose from cross-FIRs registered after a single incident on 5 November 2017.

Source reference: p. 1

In FIR No. 982/2017, Sanjay alleged that Suhail stabbed him behind the left shoulder; the medical record noted a deep incised wound measuring approximately 2 × 2 cm.

Source reference: p. 1–2

In FIR No. 980/2017, Suhail alleged that Sanjay stabbed him on the right side of the chest; the medical record noted a lacerated wound measuring 3 × 2 cm.

Source reference: p. 1–2

The parties executed separate settlement deeds on 16 April 2026 and agreed to quashing both FIRs.

Source reference: p. 2

The State opposed the petitions, citing the seriousness of the allegations under Section 307 IPC and the alleged use of a knife in a public place.

Source reference: p. 4
02

Issues

Whether the cross-FIRs alleging offences under Section 307 IPC could be quashed on the basis of the parties’ settlements, having regard to the injuries and circumstances of the incident.

Source reference: p. 4–6

Whether continuation of the prosecutions would serve a useful purpose in light of the passage of time, the limited progress of the cases, and the parties’ settlement.

Source reference: p. 6
03

Law Applied

Section 307 IPC concerns an offence of a serious nature and such offences are ordinarily treated as crimes against society, not merely against the individual; settlement alone therefore does not ordinarily warrant quashing.

Source reference: p. 4–6

However, under the High Court’s inherent quashing jurisdiction, the Court must assess the actual circumstances rather than rely solely on the inclusion of Section 307 IPC.

Source reference: p. 4–6

Relevant considerations include the nature and location of the injuries, the weapon used, the evidence supporting the charge, and the prospects of conviction.

Source reference: p. 4–6

Where a prima facie assessment indicates that conviction is remote or bleak and the settlement is complete, quashing may be appropriate.

Source reference: p. 4–6

The Court relied on Narinder Singh v. State of Punjab, (2014) 6 SCC 466, as reproduced in State of M.P. v. Laxmi Narayan, (2019) 5 SCC 688.

Source reference: p. 4–6

It also referred to Naushey Ali v. State of U.P., 2025 INSC 182, and Ms. Priya Sahani @ Pooja v. The State (NCT of Delhi), 2026:DHC:8696.

Source reference: p. 7
04

Reasoning

The Court treated the incident as a sudden quarrel between neighbours in which both sides were injured.

Source reference: p. 5

It noted that one injury was simple and the other was a single, small injury without danger to life or limb.

Source reference: p. 5

Applying the Narinder Singh factors, the Court concluded that the allegations and injuries did not establish a strong likelihood of conviction under Section 307 IPC.

Source reference: p. 6

It also considered that approximately nine years had passed with insubstantial progress in either case, and that continuing the prosecutions would serve no fruitful purpose and risk prolonging the parties’ hostility.

Source reference: p. 6–7
05

Holding

The Court allowed the petitions and quashed FIR No. 982/2017 and all proceedings arising from it qua Suhail @ Shanu, and FIR No. 980/2017 and all proceedings arising from it.

The relief was conditional on each petitioner depositing ₹5,000 with the Delhi High Court Legal Services Committee within four weeks.

Source reference: p. 7

The parties were also directed to maintain peace and not interfere with each other’s families.

Source reference: p. 7
06

Acts & Sections Cited

4 provisions across 3 statutes referred to in this judgment. Each provision opens on LawLens.

Indian Penal Code, 18602

Code of Criminal Procedure, 19731

Bharatiya Nagarik Suraksha Sanhita, 20231

Delhi High Court

Original Court PDF

Sanjay @ SanjuvsState Nct Of Delhi And Anr.

Delhi High Court · October 13, 2026

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