Case Note & Summary
The petitioner, Subramanian, was the sole accused in S.T.C.No.1308 of 2023 before the Judicial Magistrate, Tenkasi, charged with offences under Sections 279 (rash driving) and 337 (causing hurt by act endangering life or personal safety of others) of the Indian Penal Code, 1860 (IPC). The case arose from Crime No.48 of 2023 registered at Kadayanallur Police Station, Tenkasi District. According to the charge sheet, the petitioner drove a Honda Eon car in a rash and negligent manner and while turning east, dashed against a two-wheeler driven by the defacto complainant, Punamalai, causing simple injuries. The petitioner filed the Criminal Original Petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) seeking quashing of the charge sheet. The petitioner's counsel argued that medical records showed only simple injuries, the Motor Vehicle Inspector's report and Observation Mahazar contradicted the charge sheet, and the defacto complainant had already filed M.C.O.P.No.177 of 2023 before the Principal Sub-Court, Tenkasi, which was settled in Lok Adalat on 13.12.2025 with an award of Rs.60,000/-. The defacto complainant did not appear despite service. The court noted that the defacto complainant sustained simple injuries and received compensation, and no useful purpose would be served by trial. Accordingly, the court quashed the charge sheet.
Headnote
A) Criminal Procedure - Quashing of Charge Sheet - Section 528 BNSS, 2023 - Settlement in Lok Adalat - The petitioner, sole accused, sought quashing of charge sheet for offences under Sections 279 and 337 IPC. The defacto complainant sustained simple injuries and received Rs.60,000/- as compensation in Lok Adalat. The court held that no useful purpose would be served by directing the petitioner to undergo trial, and quashed the charge sheet. (Paras 5-7)
Issue of Consideration
Whether the charge sheet against the petitioner for offences under Sections 279 and 337 IPC should be quashed given that the defacto complainant sustained only simple injuries and received compensation in Lok Adalat.
Final Decision
The charge sheet in S.T.C.No.1308 of 2023 on the file of learned Judicial Magistrate, Tenkasi is quashed.
Law Points
- Quashing of criminal proceedings
- settlement in Lok Adalat
- simple injuries
- no useful purpose in trial
- Section 528 BNSS
- 2023
Case Details
2026 LawText (MAD) (03) 79
CRL.O.P(MD)No.2702 of 2026 and CRL.M.P(MD)Nos.3012 and 3014 of 2026
Mr.C.Rathinavel Pandian (for petitioner), Mr.A.Albert James (for respondent-1)
1. The State of Tamil Nadu, 2. Punamalai
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Nature of Litigation
Criminal Original Petition under Section 528 BNSS, 2023 for quashing of charge sheet in a case of rash driving and causing simple injuries.
Remedy Sought
The petitioner, sole accused, sought quashing of the charge sheet in S.T.C.No.1308 of 2023 for offences under Sections 279 and 337 IPC.
Filing Reason
The petitioner was charged with rash and negligent driving causing simple injuries to the defacto complainant.
Previous Decisions
The defacto complainant had filed M.C.O.P.No.177 of 2023 before the Principal Sub-Court, Tenkasi, which was settled in Lok Adalat on 13.12.2025 with an award of Rs.60,000/-.
Issues
Whether the charge sheet should be quashed given that the defacto complainant sustained only simple injuries and received compensation in Lok Adalat.
Submissions/Arguments
Petitioner's counsel argued that medical records showed only simple injuries, Motor Vehicle Inspector's report and Observation Mahazar contradicted the charge sheet, and the defacto complainant had already received compensation in Lok Adalat.
Ratio Decidendi
When the defacto complainant has sustained only simple injuries and has received compensation in Lok Adalat, no useful purpose will be served by directing the accused to undergo the ordeal of trial, and the charge sheet can be quashed under Section 528 BNSS.
Judgment Excerpts
In such circumstances, no useful purpose will be served in directing the Petitioner to undergo the ordeal of trial.
Considering the above said fact that the defacto complainant has sustained simple injuries and has also received compensation in Lok Adalat, this Court is inclined to quash the charge sheet, as aforesaid.
Procedural History
The petitioner was charged in Crime No.48 of 2023 for offences under Sections 279 and 337 IPC. The case was pending as S.T.C.No.1308 of 2023 before the Judicial Magistrate, Tenkasi. The defacto complainant filed M.C.O.P.No.177 of 2023 which was settled in Lok Adalat on 13.12.2025. The petitioner then filed CRL.O.P(MD)No.2702 of 2026 under Section 528 BNSS for quashing.
Acts & Sections
- Indian Penal Code, 1860 (IPC): 279, 337
- Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS): 528
