Manpreet Singh v. The State Of NCT Of Delhi And ANR

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IN THE HIGH COURT OF DELHI AT NEW DELHI

+ W.P.(CRL) 872/2026 CRL.M.A. 8324/2026 CRL.M.A. 8325/2026 MANPREET SINGH .....Petitioner Through:

Mr. Yogesh Bhardwaj, Advocate.

versus THE STATE OF NCT OF DELHI AND ANR .....Respondents Through:

Mr. Sanjay Lao, SC with Mr.

Aryan Sachdeva, Advocate.

SI Shweta, PS-Tilak Nagar.

Mr. Prateek Mudgal and Mr. Rohit Jain for R-2 with R-2 in person.

CORAM:

HON'BLE MR. JUSTICE PRATEEK JALAN

O R D E R

% 19.03.2026 1.

The petitioner has filed this petition under Article 226 of the Constitution seeking quashing of FIR No. 408/2022 dated 18.04.2022, registered at Police Station Tilak Nagar, District West, Delhi, under Sections 498A/406/34 of the Indian Penal Code, 1860 ["IPC"] and all proceedings emanating therefrom, on the ground of settlement. 2.

Issue notice. Mr. Sanjay Lao, learned Standing Counsel (Criminal), accepts notice on behalf of the State. Mr. Prateek Mudgal, learned counsel, accepts notice on behalf of respondent No. 2. 3.

The petitioner No. 1 and respondent No. 2 were married on 20.09.2015 as per Sikh rites and ceremonies. Due to matrimonial discord and temperamental differences between the parties, they have been living separately since 20.11.2021. One male child has been born from the The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

wedlock, who is presently in the custody of respondent No. 2. 4.

Respondent No. 2 lodged a complaint before the Crime Against Women Cell, Kirti Nagar, against her husband and her mother-in-law alleging cruelty inflicted upon her on demands of dowry, which culminated in registration of the present FIR on 18.04.2022. Upon completion of investigation, a chargesheet was filed against both accused on 10.02.2023. After taking cognisance of the offence, the Trial Court has discharged the mother of the petitioner by order dated 06.11.2023. On 23.01.2024, the Trial Court framed a charge against the petitioner under Section 498-A of the IPC.

5.

During the pendency of the proceedings, disputes between petitioner No. 1 and respondent No. 2 were referred to mediation before the Counselling Cell, Family Court, District West, Tis Hazari Courts. The parties have settled all their disputes in the Counselling Cell, Tis Hazari Courts, for which a Mediation Centre Settlement dated 23.01.2024 was executed between them. The settlement contemplates payment of Rs. 4,50,000/- towards full and final settlement of claims. It was agreed therein that respondent No. 2 will cooperate in quashing of the subject FIR.

6.

Pursuant to the settlement, the marriage between the parties has been dissolved by a decree of divorce by mutual consent by the Principal Judge, Family Court, Tis Hazari Courts, on 01.05.2025 in HMA No. 1077/2025.

7.

The petitioner is present in Court, and is identified by his learned counsel, as well as by the Investigating Officer ["IO"]. Respondent No. 2 is also present in person, and is identified by Mr. Mudgal and the IO. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

8.

Learned counsel for the parties confirm that the settlement has been entered into voluntarily and without any coercion or undue pressure. 9.

Although the offence under Section 498A of IPC is noncompoundable, the Supreme Court has clearly held that, in certain circumstances, the High Courts, in exercise of their extraordinary powers under Article 226 of the Constitution, can quash criminal proceedings, even with respect to non-compoundable offences, on the ground that there is a compromise between the accused and the complainant, especially when no overarching public interest is adversely affected. 10.

The Supreme Court, in Gian Singh v. State of Punjab & Anr.1 has held as follows:

"58. Where the High Court quashes a criminal proceeding having regard to the fact that the dispute between the offender and the victim has been settled although the offences are not compoundable, it does so as in its opinion, continuation of criminal proceedings will be an exercise in futility and justice in the case demands that the dispute between the parties is put to an end and peace is restored; securing the ends of justice being the ultimate guiding factor.

No doubt, crimes are acts which have harmful effect on the public and consist in wrongdoing that seriously endangers and threatens the well-being of the society and it is not safe to leave the crime-doer only because he and the victim have settled the dispute amicably or that the victim has been paid compensation, yet certain crimes have been made compoundable in law, with or without the permission of the court. In respect of serious offences like murder, rape, dacoity, etc., or other offences of mental depravity under IPC or offences of moral turpitude under special statutes, like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity, the settlement between the offender and the victim can have no legal sanction at all.

However, certain offences which overwhelmingly and predominantly bear civil flavour having arisen out of civil, mercantile, commercial, financial, partnership or such like transactions or the offences arising out of matrimony, particularly relating to dowry, etc. or the family dispute, where the wrong is basically to the victim and the offender and the 1 (2012) 10 SCC 303.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

victim have settled all disputes between them amicably, irrespective of the fact that such offences have not been made compoundable, the High Court may within the framework of its inherent power, quash the criminal proceeding or criminal complaint or FIR if it is satisfied that on the face of such settlement, there is hardly any likelihood of the offender being convicted and by not quashing the criminal proceedings, justice shall be casualty and ends of justice shall be defeated. The above list is illustrative and not exhaustive. Each case will depend on its own facts and no hard-and-fast category can be prescribed."2 Further, in Narinder Singh & Ors. v. State of Punjab & Anr.3, the Supreme Court has also laid down guidelines for High Courts while accepting settlement deeds between parties and quashing the proceedings.

The relevant observations in the said decision read as under: "29. In view of the aforesaid discussion, we sum up and lay down the following principles by which the High Court would be guided in giving adequate treatment to the settlement between the parties and exercising its power under Section 482 of the Code while accepting the settlement and quashing the proceedings or refusing to accept the settlement with direction to continue with the criminal proceedings: 29.1. Power conferred under Section 482 of the Code is to be distinguished from the power which lies in the Court to compound the offences under Section 320 of the Code.

No doubt, under Section 482 of the Code, the High Court has inherent power to quash the criminal proceedings even in those cases which are not compoundable, where the parties have settled the matter between themselves. However, this power is to be exercised sparingly and with caution. 29.2.

(i) ends of justice, or (ii) to prevent abuse of the process of any court. While exercising the power the High Court is to form an opinion on either of the aforesaid two objectives.

2 Emphasis supplied.

3 (2014) 6 SCC 466.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

29.3. Such a power is not to be exercised in those prosecutions which involve heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. Such offences are not private in nature and have a serious impact on society. Similarly, for the offences alleged to have been committed under special statute like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity are not to be quashed merely on the basis of compromise between the victim and the offender. 29.4. On the other hand, those criminal cases having overwhelmingly and predominantly civil character, particularly those arising out of commercial transactions or arising out of matrimonial relationship or family disputes should be quashed when the parties have resolved their entire disputes among themselves.

29.5. While exercising its powers, the High Court is to examine as to whether the possibility of conviction is remote and bleak and continuation of criminal cases would put the accused to great oppression and prejudice and extreme injustice would be caused to him by not quashing the criminal cases."4 11.

In the present case, the proceedings between the parties arise out of a matrimonial relationship, which has already culminated in a decree of divorce. Applying the tests laid down by the Supreme Court, it may be observed that the respondent No. 2 has also categorically affirmed the voluntary nature of the settlement before the Court.

In these circumstances, the criminal proceedings are unlikely to result in conviction, and its continuation would be an empty formality, adding to the burden of the justice system and consuming public resources unnecessarily.

12.

The settlement also contemplates payment of a sum of Rs. 4,50,000/- to respondent No. 2. Petitioner No. 1 has paid Rs. 3,00,000/- till date. The remaining amount, i.e., Rs. 1,50,000/-, has been handed over 4 Emphasis supplied.

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to respondent No. 2 in Court today. There is, therefore, no impediment to granting the relief sought.

13.

Having regard to the above discussion, the petition is allowed, and FIR No. 408/2022 dated 18.04.2022, registered at Police Station Tilak Nagar, District West, under Sections 498A/406/34 of the IPC, along with all consequential proceedings arising therefrom, is hereby quashed. 14.

The parties will remain bound by the terms of the settlement. 15.

It is made clear that the settlement and the present order do not affect any rights of the minor child, whose custody remains with respondent No. 2.

16.

The petition, alongwith the pending applications, accordingly stands disposed of.

PRATEEK JALAN, J MARCH 19, 2026 'Bhupi/JM'/ The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.