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Rajender Kumar & Ors. vs. State NCT of Delhi & Anr.

Criminal Miscellaneous Case · 2026:DHC:8483Decided 29 Sept 2026New Delhi Bench
CRL.M.C. 4343/2026CNR: DLHC010251672026
Justice Girish Kathpalia

Background

The petitioners sought quashing of FIR No. 332/2019 (PS Kanjhawala) registered under Sections 323/354/354B/451/506/509/34 IPC, on the ground that the complainant had compromised the dispute with them. The FIR alleged the petitioners forcibly entered the complainant's home, abused and groped her, disrobed her, and threatened to kill her family.

Decision Breakdown

The State pointed out that in a connected cross-FIR case listed the same day, the prosecutrix had already been chief-examined at trial and fully supported the prosecution. Counsel for the complainant, on instructions, confirmed the FIR allegations were truthful. Relying on Narender Singh vs. State of Punjab (2014) 6 SCC 466 and a recent Supreme Court ruling (Anand Kumar @ Sanjay Lalwani, decided 31.08.2026), the Court held that where a victim of heinous offences has supported the prosecution at trial, a compromise cannot be a ground to quash the FIR. The petition was dismissed.

Lesson Learnt

A private "compromise" between accused and complainant cannot override a serious criminal case once the survivor has testified in support of the prosecution: courts will not quash FIRs involving grave offences (especially against women) merely because parties have settled privately.

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