$~24 Q * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC011036042025 + CRL.M.C. 9092/2025 & CRL.M.A. 38071/2025 SANJEEV TYAGI @ SANJEEV KUMAR TYAGI .....Petitioner Through: Mr. Abhishek Rana, Mr. Mohit Pal, Mr. Shahdat Ali, Mr. Rohan Khan & Mr. Harshad Kumar, Advocates alongwith Petitioner in Person. versus THE STATE NCT OF DELHI & ANR. .....Respondent Through: Ms. Manjeet Arya, APP SI Arvind Kr., PS Jafrabad. Mr. Arun Kumar & Mr. Mohit Singh, Advocates alongwith R-2 in Person. CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R % 01.09.2026 1. By way of the present petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”], corresponding to Section 482 of the Code of Criminal Procedure, 1973 [“CrPC”], the petitioner seeks quashing of FIR No. 413/2020 dated 25.09.2020, registered at Police Station Jafrabad, New Delhi, under Sections 354/354A/506/509 of the Indian Penal Code, 1860 [“IPC”], alongwith all proceedings emanating therefrom, on the ground that the dispute between the parties has been CRL.M.C. 9092/2025 Page 1 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 amicably settled.

2. Issue notice. Ms. Manjeet Arya, learned Additional Public Prosecutor, accepts notice on behalf of the State. Mr. Arun Kumar, learned counsel, accepts notice on behalf of respondent No. 2. 3. The petitioner is present in Court and has been duly identified by his learned counsel and the Investigating Officer. Respondent No. 2 is also present in Court and has been duly identified by her learned counsel and the Investigating Officer. 4. The petition is taken up for disposal with the consent of learned counsel for the parties. 5. The impugned FIR was registered on the basis of a complaint made by respondent No. 2, wherein she alleged that she had been abused and subjected to filthy language. She further alleged that, on 22.09.2020, her father, who is the petitioner herein, broke open the door of the room in which she and her mother had confined themselves and thereafter had an altercation with her. She also alleged that the petitioner threatened her with a stick and that she was subsequently locked out of the house. 6. Upon completion of investigation, a chargesheet has also been filed against the petitioner. 7. During the pendency of the proceedings, the parties amicably resolved their disputes and entered into a settlement, which was reduced into writing by way of a Compromise/Settlement Deed dated 27.11.2025. 8. Learned counsel appearing for the parties confirm that the settlement has been entered into voluntarily and without any coercion, undue influence or pressure.

9. Mr. Abhishek Rana, learned counsel for the petitioner, submits that CRL.M.C. 9092/2025 Page 2 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 the allegations under Sections 354/354A of the IPC arose in the course of an altercation and relate to verbal abuse and an allegation that the petitioner removed and snatched the dupatta of respondent No. 2. Respondent No. 2, who is present in person, states that the allegations under Section 354A of the IPC arose out of a misunderstanding in the course of the domestic dispute. She further states that, in view of the amicable settlement between the parties, she does not wish to pursue the criminal proceedings against the petitioner, who is her father, any further. 10. In view of the aforesaid, the parties seek quashing of the impugned FIR and all proceedings emanating therefrom.

11. The Supreme Court has recognised that, in appropriate cases, the High Court may exercise its inherent jurisdiction under Section 528 of the BNSS, corresponding to Section 482 of the CrPC, to quash criminal proceedings, including in respect of non-compoundable offences, where the parties have amicably settled their disputes and continuation of the proceedings would serve no useful purpose, provided that such quashing does not have an adverse impact on any overriding public interest. 12. The Supreme Court, in Gian Singh v. State of Punjab & Anr.1 has held as follows: “58. 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 although the offences are not compoundable, it does so as in its opinion, continuation of criminal proceedings will be an exercise in futility and justice in the case demands that the dispute between the parties is put to an end and peace is restored; securing the ends of justice being the ultimate guiding factor. No doubt, crimes are acts which have harmful effect on the public and consist in wrongdoing that seriously endangers and threatens the well-being of the society and it is 1 (2012) 10 SCC 303. CRL.M.C. 9092/2025 Page 3 of 7 This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 not safe to leave the crime-doer only because he and the victim have settled the dispute amicably or that the victim has been paid compensation, yet certain crimes have been made compoundable in law, with or without the permission of the court. In respect of serious offences like murder, rape, dacoity, etc., or other offences of mental depravity under IPC or offences of moral turpitude under special statutes, like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity, the settlement between the offender and the victim can have no legal sanction at all. However, certain offences which overwhelmingly and predominantly bear civil flavour having arisen out of civil, mercantile, commercial, financial, partnership or such like transactions or the offences arising out of matrimony, particularly relating to dowry, etc. or the family dispute, where the wrong is basically to the victim and the offender and the victim have settled all disputes between them amicably, irrespective of the fact that such offences have not been made compoundable, the High Court may within the framework of its inherent power, quash the criminal proceeding or criminal complaint or FIR if it is satisfied that on the face of such settlement, there is hardly any likelihood of the offender being convicted and by not quashing the criminal proceedings, justice shall be casualty and ends of justice shall be defeated. The above list is illustrative and not exhaustive. Each case will depend on its own facts and no hard-and-fast category can be prescribed.”2

Further, in Narinder Singh & Ors. v. State of Punjab & Anr.3, the Supreme Court has also laid down guidelines for High Courts while accepting settlement deeds between parties and quashing the proceedings. The relevant observations in the said decision read as under: “29. In view of the aforesaid discussion, we sum up and lay down the following principles by which the High Court would be guided in giving adequate treatment to the settlement between the parties and exercising its power under Section 482 of the Code while accepting the settlement and quashing the proceedings or refusing to accept the settlement with direction to continue with the criminal proceedings: 29.1. Power conferred under Section 482 of the Code is to be distinguished from the power which lies in the Court to compound the offences under Section 320 of the Code. No doubt, under Section 482 of 2 Emphasis supplied. 3 (2014) 6 SCC 466. CRL.M.C. 9092/2025 Page 4 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 the Code, the High Court has inherent power to quash the criminal proceedings even in those cases which are not compoundable, where the parties have settled the matter between themselves. However, this power is to be exercised sparingly and with caution.

29.2. When the parties have reached the settlement and on that basis petition for quashing the criminal proceedings is filed, the guiding factor in such cases would be to secure: (i) ends of justice, or (ii) to prevent abuse of the process of any court. While exercising the power the High Court is to form an opinion on either of the aforesaid two objectives. 29.3. Such a power is not to be exercised in those prosecutions which involve heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. Such offences are not private in nature and have a serious impact on society. Similarly, for the offences alleged to have been committed under special statute like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity are not to be quashed merely on the basis of compromise between the victim and the offender. 29.4. On the other hand, those criminal cases having overwhelmingly and predominantly civil character, particularly those arising out of commercial transactions or arising out of matrimonial relationship or family disputes should be quashed when the parties have resolved their entire disputes among themselves.

29.5. While exercising its powers, the High Court is to examine as to whether the possibility of conviction is remote and bleak and continuation of criminal cases would put the accused to great oppression and prejudice and extreme injustice would be caused to him by not quashing the criminal cases.”4 13. In the present case, the impugned FIR arises out of a domestic dispute between the petitioner and respondent No. 2, who are father and daughter. The allegations arose in the course of an altercation between the parties, and the dispute has since been amicably resolved. The FIR was registered on 25.09.2020 and nearly six years have elapsed since its CRL.M.C. 9092/2025 Page 5 of 7 This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 registration. During this period, the parties have resolved their differences and have recorded the terms of their settlement in the Compromise/Settlement Deed dated 27.11.2025. Respondent No. 2 has appeared before this Court and has categorically stated that the allegations under Section 354A of the IPC arose out of a misunderstanding in the course of the domestic dispute and that, in view of the settlement arrived at between the parties, she does not wish to pursue the criminal proceedings against the petitioner any further. She has also expressed her desire to put the dispute behind her and move forward in life. The parties have, moreover, confirmed that the settlement has been arrived at voluntarily and without any coercion, undue influence or pressure.

14. The aforesaid circumstances, considered cumulatively, bear directly upon the question whether continuation of the criminal proceedings would serve any meaningful purpose. The considerable lapse of time since registration of the FIR, the domestic nature of the dispute, the relationship between the parties and their subsequent amicable resolution, coupled with the unequivocal stand of respondent No. 2 that she does not wish to pursue the matter, make the likelihood of the prosecution culminating in a conviction remote. In these circumstances, requiring the parties to undergo the rigours of a criminal trial in respect of a dispute which has since been resolved would serve no useful purpose. Continuation of the proceedings would, therefore, neither advance the cause of justice nor serve any overriding public interest, and would instead result in an unnecessary expenditure of judicial time and public 4 Emphasis supplied. CRL.M.C. 9092/2025 Page 6 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 resources.

15. In view of the foregoing, the present petition is allowed. Accordingly FIR No. 413/2020 dated 25.09.2020, registered at Police Station Jafrabad, New Delhi, under Sections 354/354A/506/509 of IPC, alongwith all consequential proceedings emanating therefrom, is hereby quashed, subject to the petitioner depositing costs of Rs. 10,000/- with the Delhi High Court Bar Association Costs Account [A/C No. 15530110179338; IFSC No. UCBA0001553; UCO Bank, Delhi High Court Branch] within two weeks from today. The petitioner shall file an affidavit of compliance within two weeks thereafter. 16. The parties shall remain bound by the terms of the settlement. 17. The petition, alongwith any pending applications, accordingly, stands disposed of. PRATEEK JALAN, J SEPTEMBER 1, 2026 ‘pv’/SD/ CRL.M.C. 9092/2025 Page 7 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29

$~24 Q * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC011036042025 + CRL.M.C. 9092/2025 & CRL.M.A. 38071/2025 SANJEEV TYAGI @ SANJEEV KUMAR TYAGI .....Petitioner Through: Mr. Abhishek Rana, Mr. Mohit Pal, Mr. Shahdat Ali, Mr. Rohan Khan & Mr. Harshad Kumar, Advocates alongwith Petitioner in Person. versus THE STATE NCT OF DELHI & ANR. .....Respondent Through: Ms. Manjeet Arya, APP SI Arvind Kr., PS Jafrabad. Mr. Arun Kumar & Mr. Mohit Singh, Advocates alongwith R-2 in Person. CORAM: HON’BLE MR. JUSTICE PRATEEK JALAN O R D E R % 01.09.2026 1. By way of the present petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [“BNSS”], corresponding to Section 482 of the Code of Criminal Procedure, 1973 [“CrPC”], the petitioner seeks quashing of FIR No. 413/2020 dated 25.09.2020, registered at Police Station Jafrabad, New Delhi, under Sections 354/354A/506/509 of the Indian Penal Code, 1860 [“IPC”], alongwith all proceedings emanating therefrom, on the ground that the dispute between the parties has been CRL.M.C. 9092/2025 Page 1 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 amicably settled.

2. Issue notice. Ms. Manjeet Arya, learned Additional Public Prosecutor, accepts notice on behalf of the State. Mr. Arun Kumar, learned counsel, accepts notice on behalf of respondent No. 2. 3. The petitioner is present in Court and has been duly identified by his learned counsel and the Investigating Officer. Respondent No. 2 is also present in Court and has been duly identified by her learned counsel and the Investigating Officer. 4. The petition is taken up for disposal with the consent of learned counsel for the parties. 5. The impugned FIR was registered on the basis of a complaint made by respondent No. 2, wherein she alleged that she had been abused and subjected to filthy language. She further alleged that, on 22.09.2020, her father, who is the petitioner herein, broke open the door of the room in which she and her mother had confined themselves and thereafter had an altercation with her. She also alleged that the petitioner threatened her with a stick and that she was subsequently locked out of the house. 6. Upon completion of investigation, a chargesheet has also been filed against the petitioner. 7. During the pendency of the proceedings, the parties amicably resolved their disputes and entered into a settlement, which was reduced into writing by way of a Compromise/Settlement Deed dated 27.11.2025. 8. Learned counsel appearing for the parties confirm that the settlement has been entered into voluntarily and without any coercion, undue influence or pressure.

9. Mr. Abhishek Rana, learned counsel for the petitioner, submits that CRL.M.C. 9092/2025 Page 2 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 the allegations under Sections 354/354A of the IPC arose in the course of an altercation and relate to verbal abuse and an allegation that the petitioner removed and snatched the dupatta of respondent No. 2. Respondent No. 2, who is present in person, states that the allegations under Section 354A of the IPC arose out of a misunderstanding in the course of the domestic dispute. She further states that, in view of the amicable settlement between the parties, she does not wish to pursue the criminal proceedings against the petitioner, who is her father, any further. 10. In view of the aforesaid, the parties seek quashing of the impugned FIR and all proceedings emanating therefrom.

11. The Supreme Court has recognised that, in appropriate cases, the High Court may exercise its inherent jurisdiction under Section 528 of the BNSS, corresponding to Section 482 of the CrPC, to quash criminal proceedings, including in respect of non-compoundable offences, where the parties have amicably settled their disputes and continuation of the proceedings would serve no useful purpose, provided that such quashing does not have an adverse impact on any overriding public interest. 12. The Supreme Court, in Gian Singh v. State of Punjab & Anr.1 has held as follows: “58. 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 although the offences are not compoundable, it does so as in its opinion, continuation of criminal proceedings will be an exercise in futility and justice in the case demands that the dispute between the parties is put to an end and peace is restored; securing the ends of justice being the ultimate guiding factor. No doubt, crimes are acts which have harmful effect on the public and consist in wrongdoing that seriously endangers and threatens the well-being of the society and it is 1 (2012) 10 SCC 303. CRL.M.C. 9092/2025 Page 3 of 7 This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 not safe to leave the crime-doer only because he and the victim have settled the dispute amicably or that the victim has been paid compensation, yet certain crimes have been made compoundable in law, with or without the permission of the court. In respect of serious offences like murder, rape, dacoity, etc., or other offences of mental depravity under IPC or offences of moral turpitude under special statutes, like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity, the settlement between the offender and the victim can have no legal sanction at all. However, certain offences which overwhelmingly and predominantly bear civil flavour having arisen out of civil, mercantile, commercial, financial, partnership or such like transactions or the offences arising out of matrimony, particularly relating to dowry, etc. or the family dispute, where the wrong is basically to the victim and the offender and the victim have settled all disputes between them amicably, irrespective of the fact that such offences have not been made compoundable, the High Court may within the framework of its inherent power, quash the criminal proceeding or criminal complaint or FIR if it is satisfied that on the face of such settlement, there is hardly any likelihood of the offender being convicted and by not quashing the criminal proceedings, justice shall be casualty and ends of justice shall be defeated. The above list is illustrative and not exhaustive. Each case will depend on its own facts and no hard-and-fast category can be prescribed.”2

Further, in Narinder Singh & Ors. v. State of Punjab & Anr.3, the Supreme Court has also laid down guidelines for High Courts while accepting settlement deeds between parties and quashing the proceedings. The relevant observations in the said decision read as under: “29. In view of the aforesaid discussion, we sum up and lay down the following principles by which the High Court would be guided in giving adequate treatment to the settlement between the parties and exercising its power under Section 482 of the Code while accepting the settlement and quashing the proceedings or refusing to accept the settlement with direction to continue with the criminal proceedings: 29.1. Power conferred under Section 482 of the Code is to be distinguished from the power which lies in the Court to compound the offences under Section 320 of the Code. No doubt, under Section 482 of 2 Emphasis supplied. 3 (2014) 6 SCC 466. CRL.M.C. 9092/2025 Page 4 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 the Code, the High Court has inherent power to quash the criminal proceedings even in those cases which are not compoundable, where the parties have settled the matter between themselves. However, this power is to be exercised sparingly and with caution.

29.2. When the parties have reached the settlement and on that basis petition for quashing the criminal proceedings is filed, the guiding factor in such cases would be to secure: (i) ends of justice, or (ii) to prevent abuse of the process of any court. While exercising the power the High Court is to form an opinion on either of the aforesaid two objectives. 29.3. Such a power is not to be exercised in those prosecutions which involve heinous and serious offences of mental depravity or offences like murder, rape, dacoity, etc. Such offences are not private in nature and have a serious impact on society. Similarly, for the offences alleged to have been committed under special statute like the Prevention of Corruption Act or the offences committed by public servants while working in that capacity are not to be quashed merely on the basis of compromise between the victim and the offender. 29.4. On the other hand, those criminal cases having overwhelmingly and predominantly civil character, particularly those arising out of commercial transactions or arising out of matrimonial relationship or family disputes should be quashed when the parties have resolved their entire disputes among themselves.

29.5. While exercising its powers, the High Court is to examine as to whether the possibility of conviction is remote and bleak and continuation of criminal cases would put the accused to great oppression and prejudice and extreme injustice would be caused to him by not quashing the criminal cases.”4 13. In the present case, the impugned FIR arises out of a domestic dispute between the petitioner and respondent No. 2, who are father and daughter. The allegations arose in the course of an altercation between the parties, and the dispute has since been amicably resolved. The FIR was registered on 25.09.2020 and nearly six years have elapsed since its CRL.M.C. 9092/2025 Page 5 of 7 This is a digitally signed order.

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 registration. During this period, the parties have resolved their differences and have recorded the terms of their settlement in the Compromise/Settlement Deed dated 27.11.2025. Respondent No. 2 has appeared before this Court and has categorically stated that the allegations under Section 354A of the IPC arose out of a misunderstanding in the course of the domestic dispute and that, in view of the settlement arrived at between the parties, she does not wish to pursue the criminal proceedings against the petitioner any further. She has also expressed her desire to put the dispute behind her and move forward in life. The parties have, moreover, confirmed that the settlement has been arrived at voluntarily and without any coercion, undue influence or pressure.

14. The aforesaid circumstances, considered cumulatively, bear directly upon the question whether continuation of the criminal proceedings would serve any meaningful purpose. The considerable lapse of time since registration of the FIR, the domestic nature of the dispute, the relationship between the parties and their subsequent amicable resolution, coupled with the unequivocal stand of respondent No. 2 that she does not wish to pursue the matter, make the likelihood of the prosecution culminating in a conviction remote. In these circumstances, requiring the parties to undergo the rigours of a criminal trial in respect of a dispute which has since been resolved would serve no useful purpose. Continuation of the proceedings would, therefore, neither advance the cause of justice nor serve any overriding public interest, and would instead result in an unnecessary expenditure of judicial time and public 4 Emphasis supplied. CRL.M.C. 9092/2025 Page 6 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29 resources.

15. In view of the foregoing, the present petition is allowed. Accordingly FIR No. 413/2020 dated 25.09.2020, registered at Police Station Jafrabad, New Delhi, under Sections 354/354A/506/509 of IPC, alongwith all consequential proceedings emanating therefrom, is hereby quashed, subject to the petitioner depositing costs of Rs. 10,000/- with the Delhi High Court Bar Association Costs Account [A/C No. 15530110179338; IFSC No. UCBA0001553; UCO Bank, Delhi High Court Branch] within two weeks from today. The petitioner shall file an affidavit of compliance within two weeks thereafter. 16. The parties shall remain bound by the terms of the settlement. 17. The petition, alongwith any pending applications, accordingly, stands disposed of. PRATEEK JALAN, J SEPTEMBER 1, 2026 ‘pv’/SD/ CRL.M.C. 9092/2025 Page 7 of 7 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 05/09/2026 at 10:00:29