Punjab & Haryana High Court Refuses to Quash FIR Against Sarpanch and Son for Assault on On-Duty Linemen; Holds Offences Against Public Servants Cannot Be Settled Privately
Case Name: Inderjeet Suhag & Another v. State of Haryana & Others
Date of Judgment: October 9, 2025
Citation: CRM-M-46800-2025
Bench: Hon’ble Mr. Justice Sumeet Goel
Held: The Punjab & Haryana High Court refused to quash an FIR registered under Sections 121(1), 132, 221, and 324(6) of the Bharatiya Nyaya Sanhita (BNS), 2023, against a village Sarpanch and his son for allegedly assaulting and obstructing government linemen on duty. Justice Sumeet Goel held that offences committed against public servants in the discharge of official duty cannot be quashed merely on the basis of compromise, as such acts transcend personal disputes and implicate public interest. The Court directed the State Government to initiate disciplinary action against the complainant linemen for entering into a compromise without prior administrative approval.
Summary: The petitioners, Inderjeet Suhag (village Sarpanch) and his son Akshay Suhag, sought quashing of FIR No. 234 dated 22.08.2024, registered at Police Station Beri, Jhajjar, under various provisions of the BNS, 2023, for assaulting linemen Rakesh, Sunil, and Mohit, who were on official night duty at the complaint centre located in Jat Dharamshala, Beri. The FIR alleged that the accused obstructed their entry, assaulted them, issued death threats, and damaged government property.
The petitioners argued that the FIR arose from a misunderstanding and that a compromise deed dated 07.08.2025 had been executed, where the complainants admitted mistaken identity and expressed no objection to quashing. However, the State opposed the plea, contending that the offences were public in nature, involving interference with government functioning. Justice Goel agreed, observing that the incident represented an attack on institutional authority and the functioning of public servants, and thus could not be treated as a private dispute amenable to compromise.
The Court cited Gian Singh v. State of Punjab (2012) 10 SCC 303, Narinder Singh v. State of Punjab (2014) 6 SCC 466, and State of M.P. v. Laxmi Narayan (2019) AIR SC 1296, reaffirming that while the High Court’s inherent powers under Section 528 of the BNSS, 2023 (analogous to Section 482 CrPC) permit quashing in private disputes, they cannot be invoked for offences against public servants or those involving public interest. Justice Goel further referred to Vinod @ Boda v. State of Haryana (2017) 1 RCR (Criminal) 571 (P&H DB), clarifying that compromise-based quashing can be allowed only when the act was committed in a private capacity, not while performing official duties.
Decision: Dismissing the petition, the Court held that the offences were committed against government employees while performing official duty and hence not amenable to quashing under compromise. Justice Goel directed the Administrative Secretary of the concerned department to inquire into why the linemen entered into compromise without requisite departmental sanction and to take appropriate disciplinary measures. The trial court was instructed to proceed with the case uninfluenced by the High Court’s observations.