Punjab and Haryana High Court – FIR under Sections 324, 326, 506, 201 IPC Quashed on Basis of Compromise under Section 482 CrPC

Case Name: Manpreet Singh v. State of Punjab and another

Citation: CRM-M No. 39340 of 2019

Date of Judgment: 7 January 2020

Bench: Justice Suvir Sehgal

Held: The Punjab and Haryana High Court exercised its inherent powers under Section 482 CrPC to quash an FIR and all consequential proceedings arising out of offences under Sections 324, 326, 506, and 201 IPC, on the basis of a compromise arrived at between the parties. The Court reiterated that criminal cases with overwhelmingly private or civil flavour may be quashed where the dispute has been amicably resolved and continuation of proceedings would amount to abuse of process of law.

Summary: FIR No. 02 dated 03.01.2017 was registered at Police Station Sadar Ahmedgarh, District Sangrur, under Sections 324, 326, 506, and 201 IPC. During pendency of proceedings, parties arrived at a compromise, verified by the Judicial Magistrate First Class, Malerkotla, who confirmed its genuineness and voluntary nature.

Relying on the Full Bench decision in Kulwinder Singh v. State of Punjab (2007), Division Bench ruling in Sube Singh v. State of Haryana (2013), and the Supreme Court judgment in Gian Singh v. State of Punjab (2012), the Court observed that even non-compoundable offences can be quashed if they arise from disputes of civil, commercial, or matrimonial nature, provided societal interest is not adversely affected.

Finding the compromise genuine and noting that parties desired to maintain harmony and peace, the Court quashed the FIR and subsequent proceedings against the petitioner.

Decision: Petition allowed. FIR No. 02 dated 03.01.2017 and all consequential proceedings quashed qua the petitioner.