Delhi High Court Dismisses Plea to Quash 16-Year-Old Assault FIR After Trial Concludes
New Delhi, August 5, 2026: The Delhi High Court has dismissed a petition seeking quashing of an FIR registered in 2010 for offences under Sections 325, 326, and 34 of the Indian Penal Code (IPC), holding that a compromise reached between the accused and the complainant at the final stage of the criminal trial cannot be a ground to terminate the proceedings.
Justice Girish Kathpalia, while deciding CRL.M.C. 1979/2026 (Budhu @ Murai Lal & Others vs State (NCT of Delhi) & Another), observed that the petition was not only without merit but was “completely frivolous,” particularly because the trial had already concluded and the case was awaiting judgment before the trial court.
Background of the Case
The petitioners sought quashing of FIR No. 274/2010, registered at Police Station Daryaganj, on the basis of a compromise with the complainant (Respondent No. 2). They argued that the dispute had been amicably settled and further contended that the extraordinary delay of nearly sixteen years in the conclusion of the trial justified acceptance of the settlement.
The State, represented by the Additional Public Prosecutor, opposed the plea, pointing out that the prosecution had already completed its evidence, final arguments had been heard, and the matter was fixed for pronouncement of judgment. It was also emphasized that the accused had been charged under Section 326 IPC, an offence punishable with imprisonment for life.
Court’s Observations
The High Court noted that when the matter first came up on March 18, 2026, it had specifically declined to stay the proceedings before the trial court, allowing the criminal trial to continue. Consequently, the accused themselves participated in the final arguments before the trial court.
Justice Kathpalia observed that once a criminal case has reached the stage where evidence has concluded and the matter is awaiting judgment, the High Court should ordinarily refrain from invoking its inherent jurisdiction to quash proceedings merely because the parties have entered into a compromise.
The Court also stressed that the seriousness of the charge under Section 326 IPC, which carries a maximum punishment of life imprisonment, weighed against entertaining such a settlement at the concluding stage of the trial.
Reliance on Supreme Court Precedent
The High Court relied upon the Supreme Court’s decision in Narender Singh and Others v. State of Punjab and Another, wherein the apex court held that when prosecution evidence is substantially complete or the matter has reached the stage of final arguments, High Courts should ordinarily avoid exercising powers under Section 482 of the Code of Criminal Procedure to quash criminal proceedings on the basis of compromise.
According to the Supreme Court, once the trial has substantially progressed, it is for the trial court to determine whether the offence has been proved on the basis of the evidence recorded.
Petition Held Frivolous
Rejecting every contention raised by the petitioners, Justice Kathpalia concluded that the compromise arrived at between the parties at such an advanced stage of the proceedings could not override the administration of criminal justice. The Court therefore dismissed the petition, observing:
“The present petition is not just devoid of merits, but completely frivolous, so it is dismissed.”
Significance of the Judgment
The ruling reinforces the settled legal principle that private settlements cannot automatically result in quashing of serious criminal prosecutions, particularly when:
- the offences are grave in nature, such as those punishable with life imprisonment;
- the trial has been completed or is at the stage of judgment; and
- judicial time and resources have already been extensively invested in the proceedings.
The decision serves as another reminder that the High Court’s inherent powers under Section 482 CrPC are extraordinary in nature and are to be exercised sparingly, especially after a criminal trial has reached its final stage.