The Delhi High Court has quashed two cross-FIRs arising out of a family dispute after the parties informed the court that they had amicably settled their differences and no longer wished to pursue criminal proceedings against each other.
- Case Title: Chhote Singh vs The State (NCT of Delhi)
- Court: High Court of Delhi at New Delhi
- Bench: Justice Prateek Jalan
- Date of Judgment: 3 March 2026
- Case Numbers: BAIL APPLN. 3605/2025, 3613/2025, 3619/2025; CRL.M.C. 5282/2025; CRL.M.C. 5316/2025
The petitions were filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which corresponds to Section 482 of the Code of Criminal Procedure, seeking quashing of two criminal cases registered against members of two branches of the same extended family.
The court found that the dispute arose from a familial conflict intertwined with matrimonial relationships and concluded that continuation of criminal proceedings would serve no meaningful purpose in light of a voluntary settlement between the parties.
Background of the Case
The litigation arose from two cross-FIRs registered in Delhi in 2025 following a dispute between members of two related families. The individuals involved were connected through several matrimonial alliances, which formed the backdrop of the conflict.
According to the judgment, in one proceeding the sister of the complainant was married to the son of one of the petitioners, while the complainant’s brother was married to the daughter of the same petitioner.
Similarly, in the second proceeding, the families were linked through another set of marriages, making the dispute essentially a conflict within an extended family network.
The High Court noted that the complainant in one FIR belonged to one branch of the family, while the complainant in the cross-FIR belonged to the other branch.
The disputes were therefore “cross-proceedings” triggered by events connected to the same underlying family discord and a panchayat meeting held to resolve it.
Allegations in the First FIR
The first criminal case, FIR No. 300/2025, was registered on 30 April 2025 at Police Station Shahbad Dairy.
The complainant alleged that certain objectionable or intimate photographs purportedly depicting her had been circulated on two WhatsApp groups on 25 April 2025.
She further claimed that during a community meeting held the same day at DDA Park in Jwala Puri, Paschim Vihar, one of the accused displayed the images on his mobile phone to people gathered there.
Based on these allegations, the FIR invoked:
- Section 79 of the Bharatiya Nyaya Sanhita, 2023 (BNS)
- Section 67 of the Information Technology Act, 2000
The complainant suspected the involvement of several members of the opposing branch of the family in circulating the photographs.
Allegations in the Second FIR
The second case, FIR No. 204/2025, was registered on 12 May 2025 at Police Station Paschim Vihar (West).
This FIR was lodged by a member of the opposing branch of the family who alleged that the situation escalated into violence during the same panchayat meeting held on 25 April 2025 to address the ongoing dispute.
According to the complainant, members of the other family branch assaulted him during the meeting. He alleged that he was struck on the head with stones, which caused bleeding and resulted in a laceration on the left temporal region. He was subsequently taken to Jain Hospital in Shahdara where stitches were administered, and an MLC was prepared documenting the head injury.
Based on these allegations, the police invoked provisions including:
- Sections 109 and 110 of the Bharatiya Nyaya Sanhita (BNS)
- Section 3(5) BNS
The prosecution also indicated that the facts justified adding Section 109 BNS, corresponding to attempt to murder (Section 307 IPC) under the previous criminal law framework.
Settlement Between the Parties
During the pendency of the petitions before the High Court, the parties entered into two separate Memoranda of Understanding dated 28 July 2025 resolving the disputes relating to both FIRs.
All parties appeared before the court on 26 February 2026 and confirmed that the settlement had been reached voluntarily without coercion, undue influence, or duress. The complainants also filed affidavits stating that they had no objection to the quashing of the criminal cases and the consequential proceedings.
The settlement recorded that the parties agreed to condone the allegations made against each other and close all pending disputes arising from the incidents.
Legal Principles Governing Quashing of Proceedings
Justice Prateek Jalan examined whether the High Court could exercise its inherent powers to quash criminal proceedings even though some of the alleged offences were non-compoundable.
The court relied on the Supreme Court’s decision in Gian Singh v. State of Punjab, which clarified that High Courts may quash criminal proceedings if the dispute between the offender and victim has been settled and continuation of proceedings would defeat the ends of justice.
Quoting the Supreme Court, the judgment noted:
“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… continuation of criminal proceedings will be an exercise in futility and justice demands that the dispute between the parties is put to an end and peace is restored.”
The High Court also referred to Narinder Singh v. State of Punjab, which laid down guiding principles for exercising inherent powers to quash criminal proceedings after settlement.
According to the Supreme Court’s framework, courts must consider whether:
- The dispute is essentially private or civil in nature
- The possibility of conviction is remote
- Continuing the prosecution would cause injustice or abuse of process
However, the Supreme Court cautioned that serious offences such as murder, rape, or crimes of extreme moral depravity generally cannot be quashed solely on the basis of compromise.
Consideration of Allegations Under Attempt to Murder Provisions
A notable aspect of the case was that one of the FIRs invoked provisions corresponding to attempt to murder, which courts usually treat as serious offences affecting society at large.
Justice Jalan noted that the Supreme Court in Narinder Singh clarified that the mere inclusion of Section 307 IPC does not automatically bar quashing of proceedings.
Instead, the High Court may examine factors such as:
- Nature of the injuries
- Whether vital parts of the body were targeted
- Type of weapon used
- Medical evidence and surrounding circumstances
If the evidence indicates that the possibility of conviction is weak or the allegation of attempt to murder appears exaggerated, the court may still quash the case in appropriate circumstances.
Court’s Observations on the Present Dispute
Applying these principles, the Delhi High Court observed that both FIRs stemmed from the same underlying family conflict and the events surrounding the panchayat meeting.
The court noted several important factors:
- Family relationship between parties: The dispute involved members of an extended family connected through multiple matrimonial alliances.
- Common origin of both FIRs: Both criminal cases were closely linked and arose from the same incident and family discord.
- Absence of weapons and limited severity: The altercation occurred during a sudden escalation of tempers at the panchayat meeting, and no sharp-edged weapon or firearm was used.
- Nature of injuries: Although the complainant suffered a head injury requiring stitches, he informed the court that the injuries had no lasting consequences.
- Settlement reached shortly after the incident: The compromise was executed within a few months of the events.
- Need to restore family harmony: The court emphasised that continuing criminal litigation between closely related parties would disturb peace and harmony within the family.
Justice Jalan concluded that the allegations were rooted in personal and familial discord rather than offences with broader societal implications.
Court’s Findings
The High Court ultimately found that the settlement between the parties was genuine and voluntary. It further held that the likelihood of conviction in the circumstances appeared “remote and bleak.”
The judgment stated that continuing the criminal proceedings would serve no useful purpose and would only prolong a dispute that the parties themselves had resolved.
Consequently, the court held that the case was appropriate for exercising its inherent powers to secure the ends of justice.
Final Directions of the Court
Allowing the petitions, the Delhi High Court ordered that:
- FIR No. 300/2025 registered at Police Station Shahbad Dairy under Section 79 BNS and Section 67 of the IT Act
- FIR No. 204/2025 registered at Police Station Paschim Vihar under Sections 109, 110 and 3(5) BNS
along with all consequential proceedings arising from them, stand quashed.
The court also directed that the parties would remain bound by the terms and conditions of the settlement recorded in their Memoranda of Understanding.
As a result of the quashing of the FIRs, the bail applications connected to the case were rendered infructuous and were disposed of accordingly.
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