Synopsis

Two friends from the same village in Bihar, residing in Delhi, consumed alcohol together on 25.06.2019. A quarrel broke out, leading to a scuffle. In FIR No.280/2019, complainant Suraj Kumar alleged that Babu Kumar attacked him with a knife, causing injuries on his hand and neck – initially registered under Section 308 IPC, later Section 307 IPC added. In cross FIR No.281/2019, Babu Kumar alleged that Suraj Kumar hit him on the head with a brick – registered under Sections 323/341 IPC, later charges framed under Sections 324/341 IPC. Both cases were at advanced stages (final arguments and prosecution evidence). The parties, being young and close friends, settled the dispute through a Memorandum of Understanding dated 11.12.2026. They filed petitions under Section 528 BNSS (equivalent to Section 482 CrPC) seeking quashing of both FIRs. The Delhi High Court, applying the principles laid down in Gian Singh v. State of Punjab, quashed both FIRs and all consequential proceedings, holding that continuing criminal proceedings would serve no useful purpose given the genuine compromise and the absence of any other criminal cases against either party.

Court: High Court of Delhi

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

Date of Judgment: 6th May, 2026

Citation: CRL.M.C. 2108/2026 & connected matter (unreported)

Core Law: Bharatiya Nagarik Suraksha Sanhita, 2023 – Section 528 (inherent powers to quash proceedings); Indian Penal Code, 1860 – Sections 307, 308, 324, 341, 323

1. Heading of the judgment

High court of delhi

Crl.m.c. 2108/2026 and crl.m.a. 8707/2026 (connected with crl.m.c. 2107/2026)

Suraj kumar (petitioner in crl.m.c. 2108/2026) vs. The state (gnctd) through sho, ps sagarpur and anr. (respondents)

Coram: hon’ble mr. justice manoj jain

Date of judgment: 6th may, 2026

2. Legal framework

Major laws and provisions involved:

Bharatiya nagarik suraksha sanhita, 2023 (bnss) – section 528 (inherent powers of high court to quash criminal proceedings to secure ends of justice). This provision is materially similar to section 482 of the code of criminal procedure, 1973.

Indian penal code, 1860 – section 307 (attempt to murder), section 308 (attempt to commit culpable homicide), section 324 (voluntarily causing hurt by dangerous weapons or means), section 341 (wrongful restraint), section 323 (voluntarily causing hurt).

Subject matter of the judgment:

Whether the High Court, in exercise of its inherent powers under Section 528 BNSS, can qua

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