Vishal Goel & ANR. v. State (Govt. NCT. Ofdelhi) & ANR.

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IN THE HIGH COURT OF DELHI AT NEW DELHI

+ CRL.M.C. 9273/2025 & CRL.M.A. 38702/2025 VISHAL GOEL & ANR.

.....Petitioners Through:

Mr. Deepak Jindal, Ms. Pooja Garg and Mr. Vikas Nagwan, Advocates with petitioners in person.

versus STATE (GOVT. NCT. OFDELHI) & ANR.

.....Respondent Through:

Ms. Manjeet Arya, APP for State with SI Talib Chaudhary.

Mr. Vikas Sharma, Advocate with R2 in person.

CORAM:

HON'BLE MR. JUSTICE PRATEEK JALAN

O R D E R

% 07.04.2026 CRL.M.A. 10494/2026 (for exemption) Exemption allowed, subject to all just exceptions. The application stands disposed of.

CRL.M.A. 10493/2026 (for early hearing) By way of this application, the applicant - respondent No. 2 seeks early hearing of the captioned petition, which is next scheduled to be listed 22.05.2026.

For the reasons stated therein, and with the consent of learned counsel for the parties, the application is allowed. The petition is taken up for hearing.

The application stands disposed of.

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

1.

The petitioners have filed this petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 ["BNSS"] (corresponding to Section 482 of the Code of Criminal Procedure, 1973 ["CrPC"]) seeking quashing of FIR No. 141/2018 dated 14.05.2018, registered at Police Station Sunlight Colony, District South-East, New Delhi, under Sections 323/341/34 of the Indian Penal Code, 1860 ["IPC"], and all proceedings emanating therefrom, on the ground of settlement. 2.

Issue notice. Ms. Manjeet Arya, learned Additional Public Prosecutor, accepts notice on behalf of the State. Mr. Vikas Sharma, learned counsel, accepts notice on behalf of respondent No. 2 - complainant.

3.

The allegations, as they emerge from the impugned FIR, are that on 13.05.2018, at about 1:30 PM, when respondent No. 2 was leaving his residence in his car, he requested petitioner No. 1 to remove his scooty which was parked on the road. However, petitioner No. 1 refused to do so and, instead, began hurling abuses at respondent No. 2. Thereafter, petitioner No. 1 picked up a brick and broke the front window of respondent No. 2's car. Respondent No. 2 then alighted from his vehicle, whereupon petitioner No. 2 arrived, and the parties got into a scuffle. 4.

Upon completion of the investigation, a chargesheet was filed under Sections 325/341/427/34 of the IPC.

5.

The parties have since entered into a settlement, as recorded in a Memorandum of Understanding dated 18.12.2025. In light of the aforesaid, they seek quashing of the impugned FIR. 6.

The parties are present before the Court, and have been duly The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

identified by the Investigating Officer as well as by their respective learned counsel.

7.

The settlement records that the parties have amicably resolved their disputes, and contemplates payment of a sum of Rs. 5,50,000/- by the petitioners to respondent No. 2. Respondent No. 2, who is present in Court and represented by counsel, confirms that he has received the said amount in terms of the settlement.

8.

The Medico-Legal Certificates ["MLCs"] of petitioner No. 1 and respondent No. 2, issued by Jai Prakash Narayan Apex Trauma Centre, All India Institute of Medical Sciences, New Delhi, have been placed on record. Although the MLC of respondent No. 2 records grievous injuries, it appears that the same is on account of a fracture sustained in his hand. I am informed that there are no lasting injuries. Further, there was no use of firearms or sharp weapons, and no cross-FIR has been registered in respect of the incident.

9.

The Supreme Court has clearly held that, in certain circumstances, the High Courts, in exercise of their powers under Section 482 of the CrPC [corresponding to Section 528 of the BNSS], can quash criminal proceedings 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 and Anr. [(2012) 10 SCC 303], 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 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

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 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-andfast category can be prescribed." [Emphasis supplied.] Further, in Narinder Singh and Ors. v. State of Punjab and Anr.

[(2014) 6 SCC 466], 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: The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

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. When the parties have reached the settlement and on that basis petition for quashing the criminal proceedings is filed, the guiding factor in such cases would be to secure:

(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.

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."

[Emphasis supplied.] 11.

The present matter arises out of a misunderstanding between parties residing in neighbouring localities, which culminated in a scuffle. Applying the principles laid down by the Supreme Court, it is also pertinent to note that respondent No. 2 has affirmed the voluntary nature of the settlement before this Court. Accordingly, having regard to the nature of the dispute, the fact that no lasting injuries were sustained, the The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

absence of any larger societal impact, and the voluntary settlement arrived at between the parties, I am of the view that the continuation of the criminal proceedings would serve no useful purpose and is unlikely to culminate in a conviction. Rather, it would result in an unnecessary expenditure of judicial time and impede the restoration of harmony between the parties.

12.

Having regard to the above discussion, the petition is allowed, and FIR No. 141/2018 dated 14.05.2018, registered at Police Station Sunlight Colony, District South-East, New Delhi, under Sections 323/341/34 of the IPC, alongwith all consequential proceedings arising therefrom, is hereby quashed.

13.

However, having regard to the fact that the FIR dates back to 2018, and that considerable judicial time and resources have already been expended, the petitioners are directed to jointly deposit costs of Rs.25,000/- with the Delhi High Court Bar Association [A/C No. 15530110179338, IFSC No. UCBA0001553, Bank Name: UCO Bank, Branch: Delhi High Court]. The costs be deposited within two weeks from today. An affidavit of compliance be filed within two weeks thereafter.

14.

Further, in view of the circumstances giving rise to the impugned FIR, the petitioners are directed to undertake community service, in addition to depositing costs, as stated above. The petitioners are, accordingly, directed to report to the Medical Superintendent, Safdarjung Hospital, New Delhi, on 17.04.2026 at 11:30 AM. The petitioners shall perform community service for three hours per session, for eight sessions, over the next three months. The Medical Superintendent is requested to The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

assign appropriate duties to them, and to issue a certificate of compliance upon completion of the aforesaid period. The petitioners shall place the same on record within two weeks thereafter.

15.

The petition, alongwith pending application, accordingly stands disposed of.

16.

The next date of hearing, i.e. 22.05.2026, stands cancelled. PRATEEK JALAN, J APRIL 7, 2026 'sv/KA'/ The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.