SP Dabas v. State Govt of NCT of Delhi and Anr

Delhi High Court · 11 Aug 2025 · 2025:DHC:6707
Ravinder Dudeja
CRL.M.C. 5448/2025
2025:DHC:6707
criminal petition_allowed Significant

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The Delhi High Court quashed an FIR under the SC/ST Act following an amicable settlement between parties, applying the principle that continuation of criminal proceedings would be an abuse of process.

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CRL.M.C. 5448/2025
HIGH COURT OF DELHI
Date of Decision: 11.08.2025 ,,,,,,,,,, CRL.M.C. 5448/2025 & CRL.M.A. 23386/2025
INTERIM STAY
SP DABAS .....Petitioner
Through: Mr. Umang Tyagi, Mr. Zuber Ali & Ms. Diksha Punia, Advocates.
Petitioner in person.
VERSUS
STATE GOVT OF NCT
OF DELHI AND ANR … Respondents
Through: Mr. Aman Usman, APP
WITH
ACP Akash Rawat, ACP Ashok
Vihar & Inspector Yunus Javed, PS Keshav Puram.
Respondent No. 2 in person.
CORAM:-
HON'BLE MR. JUSTICE RAVINDER DUDEJA
JUDGMENT
(ORAL)
RAVINDER DUDEJA, J.

1. This is a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, seeking quashing of FIR No. 301/2025, dated 11.04.2025, registered at P.S Keshav Puram, Delhi under Sections 3(1)(r)(s) SC/ST Act and all proceedings emanating therefrom on the basis of settlement between the parties.

2. As per averments made in the FIR, Respondent No. 2, an advocate was subjected to caste-indicative and derogatory language, referencing to her SC/ST background by petitioner upon her visit to MCD office in Keshav Puram, New Delhi. Subsequently, FIR No.301/2025 was lodged at instance of Respondent No. 2 under section 3(1)(r)(s) SC/ST Act against the petitioner.

3. During the course of proceedings, the parties amicably resolved their disputes and Respondent No. 2 has executed her Affidavit dated 21.07.2025 and a formal letter dated 22.07.2025 to the Investigating Officer/Assistant Commissioner of Police. Copy of the Affidavit dated 21.07.2025 and formal letter dated 22.07.2025 have been annexed as Annexure A-3 & Annexure A-4.

4. Parties are physically present before the Court. They have been identified by his respective counsels as well as by the Investigating Officer ACP Akash Rawat & Inspector Yunus Javed, from PS Ashok Vihar & PS Keshav Puram.

5. Respondent No. 2 confirms that the matter has been amicably settled with the petitioner without any force, fear, coercion and she has no objection if the FIR No. 301/2025 is quashed against the Petitioner.

6. In view of the settlement between the parties, learned Additional PP appearing for the State, also has no objection if the present FIR No. 301/2025 is quashed.

7. In Gian Singh vs State of Punjab (2012) 10 SCC 303, Hon’ble Supreme Court has recognized the need of amicable resolution of disputes by observing as under:-

"61. In other words, the High Court must consider whether it would be unfair or contrary to the interest of justice to continue with the criminal proceedings or continuation of criminal proceedings would tantamount to abuse of process of law despite settlement and compromise between the victim and the wrongdoer and whether to secure the ends of justice, it is appropriate that criminal case is put to an end and if the answer to the above question(s) is in the affirmative, the High Court shall be well within its jurisdiction to quash the criminal proceedings."

8. In view of the aforesaid circumstances and the fact that parties have put a quietus to the dispute, no useful purpose will be served in continuing with the present FIR No. 301/2025, dated 11.04.2025, registered at P.S Keshav Puram, Delhi under section 3(1)(r)(s) SC/ST Act and all the other consequential proceeding emanating therefrom.

9. In the interest of justice, the petition is allowed, and the FIR NO. 301/2025, dated 11.04.2025, registered at P.S Keshav Puram, Delhi under section 3(1)(r)(s) SC/ST Act and all the other consequential proceeding emanating therefrom is hereby quashed.

10. Petition is allowed and disposed of accordingly.

11. Pending application(s), if any, also stand disposed of.

RAVINDER DUDEJA, J August 11, 2025