Serious knife assault causing life-threatening injury cannot be quashed solely on the basis of compromise.

The petitioner sought quashing of FIR No. 205 dated 11.12.2025, registered at Police Station Adampur, District Jalandhar Rural, under Sections 109, 333, 118(1) and 115(2) of the Bharatiya Nyaya Sanhita, 2023, corresponding to Sections 307, 452, 324 and 323 IPC, along with consequential proceedings, under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, on the basis of a compromise dated 22.12.2025.

The FIR was registered on the statement of Manjit Singh, whose daughter Bandana was allegedly assaulted by the petitioner, a neighbour, with a knife inside the complainant’s house.

The alleged assault caused injuries to Bandana’s neck and arms.

The medico-legal report recorded 13 injuries, including three incised wounds, and the neck injury was opined to be dangerous to life.

Although the parties subsequently entered into a compromise, the State opposed quashing, relying on the serious nature of the allegations, the direct role attributed to the petitioner, and the societal implications of the alleged offence.

Whether the High Court should exercise its inherent jurisdiction under Section 528 BNSS to quash the FIR and consequential proceedings on the basis of a compromise between the parties, despite the allegations involving an offence corresponding to Section 307 IPC?

Whether the nature of the alleged knife assault, the number and character of injuries, the targeting of the victim’s neck, and the medical opinion that the injury was dangerous to life justified refusing quashing notwithstanding the compromise?

The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, corresponding to Section 482 Cr.P.C., which confers extraordinary and discretionary inherent jurisdiction to prevent abuse of process and secure the ends of justice.

It relied on Narinder Singh v. State of Punjab, 2014 INSC 217, recognising that criminal proceedings may, in appropriate cases, be quashed on the basis of a genuine compromise, but that the Court must consider the nature and gravity of the offence and the surrounding circumstances.

It also considered Simarjit Kaur v. State of Punjab, CRM-M-55342-2024, decided on 12.11.2024, where quashing was permitted in exceptional circumstances despite the involvement of Section 307 IPC.

The governing principle is that compromise is relevant but not decisive; quashing is ordinarily inappropriate where the allegations disclose serious violence, use of a deadly weapon, injury to a vital body part, or conduct having broader societal implications.

The Court held that the allegations were not of a trivial or purely personal dispute.

The prosecution attributed a direct and specific knife assault to the petitioner, resulting in 13 injuries, including three incised wounds, with the victim’s neck—a vital and vulnerable part of the body—being targeted.

The medical opinion that the neck injury was dangerous to life substantially enhanced the gravity of the alleged offence.

Although the compromise was voluntary and relevant, it could not, by itself, efface the seriousness of the alleged act or eliminate the societal interest in prosecuting conduct allegedly amounting to an attempt on human life.

The Court therefore concluded that the case did not fall within the exceptional category warranting termination of prosecution at the threshold.

It clarified that it was not assessing the ultimate guilt or evidentiary merits, which were to be determined by the Trial Court.

The compromise was held insufficient to justify quashing the FIR in view of the serious allegations, the alleged knife attack, the multiple injuries, the life-threatening neck injury, and the societal implications of the prosecution.

The petition seeking quashing of FIR No. 205 dated 11.12.2025 and all consequential proceedings was dismissed.

All pending miscellaneous, interlocutory and ancillary applications were disposed of as infructuous.