Synopsis

A person died after being trapped in a goods lift at a factory. The police registered an FIR under sections 287 and 304a ipc against the owners of the premises, alleging negligent upkeep of the lift. The legal representatives of the deceased entered into a compromise with the accused, accepting compensation. The high court quashed the fir, holding that (i) the matter had been amicably settled with the victim’s family; (ii) the case was based on weak evidence – no eyewitness, the main witness (son of deceased) no longer supported prosecution; (iii) merely being owner of the premises does not automatically establish gross negligence required for conviction under sections 287/304a ipc. The court exercised its inherent power under section 528 bnss (equivalent to section 482 crpc) and quashed the proceedings.

Court: High Court of Delhi at New Delhi

Coram: Hon’ble Mr. Justice Manoj Jain (Single Judge)

Date of Decision: 12th May 2026

Citation: CRL.M.C. 2444/2025 (2026:DHC: - not explicitly given, but judgment date provided)

Core Law: Criminal Procedure / Negotiable Instruments? Actually, it's quashing of FIR under Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 – Section 528 (inherent powers, analogous to Section 482 CrPC); Indian Penal Code, 1860 – Sections 287 (negligent conduct with respect to machinery) and 304A (causing death by negligence).

1. Heading of the judgment

High court of delhi at new delhi

Crl.m.c. 2444/2025 & crl.m.a. 10936/2025

Neeraj bhalla & ors. (petitioners) vs. State govt. of nct of delhi and anr. (respondents)

Coram: hon’ble mr. justice manoj jain

Date: 12th may, 2026

2. Legal framework

Major laws and provisions involved:

• Bharatiya nagarik suraksha sanhita (bnss), 2023 – section 528 (inherent powers to quash criminal proceedings to secure ends of justice)

• Indian penal code, 1860 – section 287 (negligent conduct with respect to machinery), section 304a (causing death by negligence)

• Code of criminal pr

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