Punjab & Haryana High Court Declines Quashing of FIR in Fatal Accident Case Despite Compromise

Case Name: Satnam Singh vs. State of Punjab & Another
Date of Judgment: 20 November 2025
Citation: CRM-M-59021-2025
Bench: Hon’ble Mr. Justice Sumeet Goel

Held: The Punjab and Haryana High Court refused to quash criminal proceedings under Sections 304-A and 279 IPC, despite a settlement between the accused and the legal heirs of the deceased. The Court held that offences involving death due to negligent driving cannot be considered private disputes and therefore are not amenable to quashing solely on the basis of compromise. It was reiterated that such offences involve societal interest, and allowing quashing merely because compensation has been paid would weaken deterrence in matters concerning road safety and public responsibility.

Summary: The proceedings arose from an FIR registered in connection with a road accident wherein the deceased sustained fatal injuries allegedly due to rash and negligent driving by the petitioner, who was operating a JCB at the time of the incident. After trial, the petitioner was convicted. Subsequently, a compromise was entered into between the petitioner and the family of the deceased, wherein monetary compensation was paid and no further grievance was expressed by the complainant or legal heirs. On this basis, the petitioner sought quashing of the FIR and conviction. In response, the State opposed the request and submitted that the Supreme Court has repeatedly held that cases involving death, particularly those arising from rash and negligent driving, cannot be treated as civil matters. The Court noted the compromise but found that the nature of the offence prevented quashing as a matter of law.

In addressing the legal framework, the Court reviewed authoritative precedents including Gian Singh v. State of Punjab, Narinder Singh v. State of Punjab, State of Madhya Pradesh v. Laxmi Narayan, and Daxaben v. State of Gujarat. Applying these principles, the Court held that permitting quashing in such circumstances would undermine the statutory intent behind Section 304-A IPC and reduce criminal accountability to a negotiable settlement. The Court also observed that in matters involving loss of life, the victim is no longer alive to participate, and therefore private compromise cannot fully represent justice or public interest.

Decision: The petition seeking quashing of the FIR, conviction order and subsequent proceedings was dismissed. The Court directed that appellate or revisional remedies, if already invoked or available, may proceed in accordance with law without being influenced by observations in the present order. All pending applications were also disposed of.