Case Note & Summary
The applicant filed a criminal application under Section 482 of the Code of Criminal Procedure, 1973 seeking quashing of FIR No. 51 of 2025 registered at Hinjewadi Police Station, Pune for offences under Sections 126(2), 351(1), 351(2) of the Bhartiya Nyaya Sanhita, 2023. The FIR was lodged by the informant, Mrs. Rushali Purushottam Gupta, against the applicant, Mr. Ayyappa Swami. During the pendency of the application, the parties amicably settled the dispute. The court heard the learned counsel for the applicant, the learned APP for the State, and the learned counsel for the informant. The court noted that the offences were not of a serious nature and did not affect public interest. Considering the settlement and the fact that no public interest was involved, the court exercised its inherent powers under Section 482 CrPC to quash the FIR and all consequential proceedings. The court held that continuing the prosecution would be an abuse of the process of law. The application was allowed, and the rule was made absolute.
Headnote
A) Criminal Procedure Code - Quashing of FIR - Settlement between parties - Inherent powers under Section 482 CrPC - FIR quashed where parties settled dispute and no public interest involved - Held that continuation of proceedings would be an abuse of process of law (Paras 1-3).
Issue of Consideration
Whether the FIR registered for offences under Sections 126(2), 351(1), 351(2) of the Bhartiya Nyaya Sanhita, 2023 should be quashed on the basis of a settlement between the applicant and the informant.
Final Decision
The court allowed the application and quashed FIR No. 51 of 2025 registered at Hinjewadi Police Station, Pune and all consequential proceedings.
Law Points
- Quashing of FIR on settlement
- Compromise in non-compoundable offences
- Section 482 CrPC inherent powers
- No public interest in continuing prosecution
Case Details
Criminal Application No. 343 of 2025
Revati Mohite Dere, Sandesh D. Patil
Mr. Mohan Anant Vishnu for the Applicant, Ms. Gauri S. Rao, A.P.P. for Respondent No.1-State, Mr. Sumit Gadade i/b Mr. Shubham Gadade for Respondent No.2
State of Maharashtra and Mrs. Rushali Purushottam Gupta
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Nature of Litigation
Criminal application for quashing of FIR
Remedy Sought
Quashing of FIR No. 51 of 2025 registered at Hinjewadi Police Station, Pune for offences under Sections 126(2), 351(1), 351(2) of Bhartiya Nyaya Sanhita, 2023
Filing Reason
The applicant sought quashing of the FIR on the ground that the parties had amicably settled the dispute and no public interest was involved.
Issues
Whether the FIR should be quashed on the basis of settlement between the parties.
Submissions/Arguments
Learned counsel for the applicant submitted that the parties have amicably settled the dispute.
Learned APP for the State and learned counsel for the informant did not oppose the quashing.
Ratio Decidendi
Where parties have settled the dispute and the offences are not of a serious nature affecting public interest, the High Court in exercise of its inherent powers under Section 482 CrPC can quash the FIR to prevent abuse of process of law.
Judgment Excerpts
Heard learned Counsel for the Applicant, learned A.P.P. for the Respondent No.1-State and learned Counsel for the Respondent No.2.
By the present Criminal Application, the Applicant is praying for quashing and setting aside of the F.I.R. registered vide C.R. No.51 of 2025, with the Hinjewadi Police Station, Pune on 24th January, 2025, against the Applicant for the offences punishable under Sections 126(2), 351(1), 351(2) of the Bhartiya Nyaya Sanhita, 2023.
Procedural History
The applicant filed Criminal Application No. 343 of 2025 before the High Court of Judicature at Bombay seeking quashing of FIR No. 51 of 2025. The application was reserved on 20th November 2025 and pronounced on 18th December 2025.
Acts & Sections
- Bhartiya Nyaya Sanhita, 2023: 126(2), 351(1), 351(2)
- Code of Criminal Procedure, 1973: 482
