CRL.M.C./2844/2026 of RAM MILAN Vs THE STATE OF NCT OF DELHI & ORS. on 13 October 2026

1. The present petition has been filed by the petitioner seeking quashing of FIR No. 783/2014, dated 18.06.2014, registered at P.S. Narela, Outer District (Delhi), under Section 324 of the Indian Penal Code, 1860 (hereinafter “IPC”), and the proceedings emanating therefrom in case pending, on the basis of a Settlement/MOU dated 07.04.2026. The copy of the said Settlement/MOU is appended as Annexure P-4 to the present petition. The same, inter alia, reads as under:

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2. The parties are present in Court today and have been duly identified by the Investigating Officer (IO). They submit that they have entered into the aforesaid settlement/MOU of their own free will and volition without any coercion.

3. It is submitted that the trial Court has been informed about the settlement of the disputes between the parties quite some time ago.

4. Learned APP for the State does not raise any objection to the present petition.

5. While discussing the inherent power of the High Court to quash non- compoundable offences under section 482 of the CrPC, the Supreme Court in Gian Singh v. State of Punjab, (2012) 10 SCC 303, made the following observations:

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“54. In different situations, the inherent power may be exercised in different ways to achieve its ultimate objective. Formation of opinion by the High Court before it exercises inherent power under Section 482 on either of the twin objectives, (i) to prevent abuse of the process of any court, or (ii) to secure the ends of justice, is a sine qua non *** .

56. It needs no emphasis that exercise of inherent power by the High Court would entirely depend on the facts and circumstances of each case. It is neither permissible nor proper for the court to provide a straitjacket formula regulating the exercise of inherent powers under Section 482 *** . No precise and inflexible guidelines can also be provided.

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 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

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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 (emphasis supplied) . 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.”

6. It is also worthwhile to refer to the Supreme Court’s decision in Narinder Singh v. State of Punjab, (2014) 6 SCC 466, wherein the Court remarked: “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) .”

7. Considering the aforesaid circumstances and the dicta laid down by the Supreme Court, there is no impediment in acceding to the request of the parties for quashing of the aforementioned FIR. The disputes between the parties are essentially private, and continuing the case would be an exercise in futility.

8. In the circumstances, FIR No. 783/2014, dated 18.06.2014, registered at P.S. Narela, Outer District (Delhi), under Section 324 of the IPC, and the proceedings emanating therefrom, stand quashed.

9. The petition stands disposed of in the above terms.

SACHIN DATTA, J OCTOBER 13, 2026/at/sd

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