Punjab & Haryana High Court Quashes FIR Under Section 174-A IPC After Compromise in Cheque Dishonour Case

Case Name: Krishan Kumar vs. State of Haryana and Another
Date of Judgment: 13 November 2025
Citation: CRM-M-57601-2025
Bench: Hon’ble Mr. Justice Sumeet Goel

Held: The Punjab and Haryana High Court quashed the FIR registered under Section 174-A IPC against the petitioner, holding that once the underlying proceedings under Section 138 of the Negotiable Instruments Act stood withdrawn on account of settlement between the parties, continuation of prosecution under Section 174-A IPC would amount to abuse of process. The Court held that while Section 174-A IPC is technically a standalone offence and may survive even if proclamation proceedings are later nullified, the fact that the foundational complaint was compoundable and stands settled is a relevant factor permitting quashing in exercise of inherent jurisdiction.

Summary: The petitioner was declared a proclaimed person during the pendency of a complaint under Section 138 of the Negotiable Instruments Act after non-appearance before the trial court. Based on the proclamation order, an FIR under Section 174-A IPC was registered. The petitioner sought quashing of both the proclamation order and the FIR, arguing that the main complaint had already been withdrawn after compromise, rendering further proceedings unnecessary and oppressive. The complainant’s withdrawal order, reproduced in the record, confirmed the settlement. The State opposed the petition but conceded the underlying withdrawal. The Court examined earlier High Court rulings and the recent judgment of the Supreme Court in Daljit Singh vs. State of Haryana, wherein it was clarified that while Section 174-A IPC constitutes an independent offence, courts may close proceedings where the foundational case has been settled and continuation would serve no legitimate purpose.

Decision: The petition was allowed. The Court quashed the proclamation order dated 03.02.2023, FIR No. 111 dated 15.03.2023 under Section 174-A IPC registered at Police Station Urban Estate, Hisar, and all consequential proceedings. The Court invoked inherent jurisdiction under Section 528 BNSS (earlier Section 482 CrPC), observing that criminal law is intended to advance justice rather than perpetuate litigation in matters arising from private financial disputes that have already been amicably resolved. All pending applications were disposed of.