The Delhi High Court quashed an FIR registered under Sections 324 and 506 of the Indian Penal Code after noting that the parties had amicably settled their dispute and the victim no longer wished to pursue the case. The matter originated from a complaint filed by the son of a dry-cleaning shop owner, who alleged that when he went to collect a blanket he had given for cleaning two months earlier, he was abused, and later, while returning home, was assaulted and stabbed by the accused. Following this incident, an FIR was registered. Over time, however, the complainant and the accused reached a settlement in which the accused expressed remorse and assured that no such conduct would occur in the future. The complainant stated before the Court that he did not wish to continue with the criminal proceedings and had no objection to quashing the FIR.
Justice Amit Mahajan examined the terms of the settlement and found it to be voluntary and genuine. The Court observed that since the parties had resolved their differences and the complainant did not want to pursue the matter, continuing with the prosecution would not serve any purpose. It noted that prolonging the trial despite an amicable settlement would only lead to unnecessary harassment for both sides and would amount to an abuse of the judicial process. The Court emphasized that in cases involving personal disputes of such nature, where the victim clearly indicates that he has forgiven the accused and desires to move on, the justice system should not compel continuation of criminal proceedings unless broader public interest demands it.
While agreeing to quash the FIR, the Court imposed conditions to ensure that some measure of restitution is made, considering that the State machinery had already been involved in investigating the incident. The Court directed the accused to deposit ₹25,000 with Arya Kanya Sadan, a charitable institution that works for the welfare of destitute girls. Additionally, it ordered payment of ₹25,000 as compensation directly to the complainant. The Court held that such compensation reflects both accountability and acknowledgment of the harm caused, even though the parties have chosen to put the matter behind them.
The Court also acknowledged that the dispute was essentially personal and did not involve offences of a nature that would prevent consideration of settlement. Since neither the complainant nor the accused wished for continued proceedings, and no larger public interest was implicated, the Court found no justification for keeping the criminal case pending. It noted that the settlement had been reached without coercion and that the complainant’s decision was informed and voluntary.
After examining the case record, including the settlement terms and statements made before the Court, Justice Mahajan concluded that the ends of justice would be served by quashing the FIR. The Court reiterated that the purpose of criminal law is not served by insisting upon prosecution in situations where the alleged victim has clearly indicated a desire to withdraw from the process. It added that forcing the parties to undergo trial despite their mutual understanding would unnecessarily burden the judicial system and cause avoidable hardship.
The case, titled Jatinder Pal Singh v. State NCT of Delhi and Others, thus ended with the FIR being quashed subject to the fulfillment of the financial conditions imposed. The Court directed that proof of payment be filed and made part of the record. Once the payments are made, the quashing of the FIR will stand confirmed.
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