Om Prakash Batra vs. The State Govt. of NCT Delhi & Anr.
Background
The petitioner sought quashing of a 2015 FIR under Sections 406/420/467/471 IPC, registered on a Magistrate's direction after the complainant alleged the petitioner issued a forged cheque against a friendly loan of Rs. 3 lakhs. The original complainant died in 2024, and the case was thereafter pursued by his widow and two children.
Decision Breakdown
The parties had signed a settlement deed in January 2024 (before the complainant's death) under which Rs. 3.5 lakhs was paid. The complainant's legal heirs, appearing via video-conferencing, confirmed they had received the amount and had no objection to quashing. Finding the dispute private in nature with no ongoing public interest, the Court quashed the FIR under Section 528 BNSS.
Lesson Learnt
A settlement reached before a complainant's death remains valid and can be honoured by the complainant's legal heirs to secure quashing of the criminal case, provided they confirm the settlement voluntarily before the Court.