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Sahil Mahajan and Ors. vs. State NCT of Delhi and Ors.

Criminal Miscellaneous Case · CNR No. DLHC010443842026Decided 18 Sept 2026New Delhi Bench
CRL.M.C. 6902/2026CNR: DLHC010443842026
Justice Purushaindra Kumar Kaurav

Background

Two sets of petitioners sought quashing of two related FIRs (No. 318/2024 and No. 317/2024, both registered at Police Station Rajouri Garden) arising from a sudden altercation between the parties that escalated into abusive language and physical scuffling, resulting in cross-FIRs under various IPC provisions (including hurt, wrongful restraint, criminal intimidation, and outraging modesty). The parties later entered into a settlement deed dated 24.08.2026, and the complainants stated they no longer wished to pursue the cases.

Decision Breakdown

The Court extensively reviewed Supreme Court precedent on quashing non-compoundable offences based on settlement (including Gian Singh v. State of Punjab and Narinder Singh v. State of Punjab), noting that quashing is appropriate where conviction is unlikely, continuing the case would be unjust, and the dispute is not one involving heinous crime, corruption, or offences against society at large. Finding the present dispute to be a personal altercation that had been genuinely and voluntarily settled, with the State not opposing quashing, the Court quashed both FIRs and all consequent proceedings against the petitioners.

Lesson Learnt

Even offences that are technically "non-compoundable" under the criminal law can still be quashed by the High Court under its inherent powers if the dispute is essentially personal, the parties have genuinely reconciled, and continuing the prosecution would serve no real purpose. This leniency does not extend to heinous crimes or offences against the public interest.

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