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State of M.P. & Anr. v. Rajveer Singh & Ors.

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 446 of 2016)Decided 25 Apr 2016
Criminal Appeal No. 446 of 2016
Justice V. Gopala Gowda · Justice Arun Mishra

Background

The complainant alleged that an Assistant Sub-Inspector, Rajveer Singh, shot him in the leg and assaulted him during an altercation in 2006; after delays in registration, an FIR under Section 307/34 IPC was eventually registered in 2011 following High Court intervention. Rajveer Singh sought quashing of the FIR under Section 482 CrPC, claiming the complainant's injury had actually been caused by dacoits in an unrelated encounter and relying on a compromise reached with the complainant during the pendency of proceedings. The Madhya Pradesh High Court quashed the FIR on this basis, and the State of M.P. appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that the High Court had failed to consider the serious, disputed factual allegations and counter-allegations, including conflicting versions over whether the police or dacoits caused the complainant's injury, which could not simply be resolved by a compromise. Relying on its earlier ruling in State of Rajasthan v. Shambhu Kewat, the Court reiterated that an offence like one under Section 307 IPC (attempt to murder) is a crime against society, not merely against an individual, and cannot be wiped out through private settlement since criminal law exists to protect society at large, not just the victim. Since the FIR disclosed a cognizable offence requiring further investigation, the High Court had erred in quashing it on the strength of a compromise. The Supreme Court set aside the High Court's order, allowed the appeal, and directed that investigation proceed and be taken to its logical conclusion.

Lesson Learnt

Serious, non-compoundable criminal offences (like attempt to murder) cannot be settled away by a private compromise between the complainant and accused: courts should not quash an FIR disclosing such an offence merely because the parties have reached an understanding, since the criminal justice system exists to protect society as a whole, not just the individual victim.

Official source (sci.gov.in)View Judgment (PDF)

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