On 7 August 2026, the High Court of Delhi in Ankur Rawat & Anr. v. State of NCT of Delhi, decided with a connected petition, quashed two cross-FIRs registered at Police Station Sarita Vihar arising from a road rage incident, after the parties placed a settlement on record. Justice Girish Kathpalia held that it would not serve the interests of justice to push the parties through a full trial — but, alive to how dangerous road rage can become, quashed the cases only on payment of costs. The order is a compact illustration of how compromise quashing operates for offences registered under the Bharatiya Nyaya Sanhita, 2023.
The dispute and the settlement
Two FIRs — No. 43/2026 and No. 24/2026, both of Police Station Sarita Vihar — were registered against each side of a road rage altercation. The offences invoked were Sections 115(2), 126(2) and 351(2) of the Bharatiya Nyaya Sanhita, 2023, read with Section 3(5). In substance: voluntarily causing hurt, wrongful restraint and criminal intimidation, attributed to the accused with common intention. Both sides approached the High Court under its inherent jurisdiction, informing it that they had resolved their differences and did not wish to prosecute each other.
BNS sections and their IPC ancestry
Indian Penal Code, 1860
Section 323 — voluntarily causing hurt
Section 341 — wrongful restraint
Section 506 — criminal intimidation
Section 34 — common intention
Bharatiya Nyaya Sanhita, 2023
Section 115(2) — voluntarily causing hurt
Section 126(2) — wrongful restraint
Section 351(2) — criminal intimidation
Section 3(5) — common intention
The BNS has applied to offences committed on or after 1 July 2024, and quashing petitions in such cases invoke Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, the successor to Section 482 of the Code of Criminal Procedure, 1973. The tests remain those long settled under the old Code: the High Court asks whether the dispute is essentially private, whether the settlement is genuine, and whether continuing the prosecution would serve any realistic purpose once the complainant has resiled from the accusation.
What the Court held
Justice Kathpalia found that the settlement made a trial pointless as between the parties, observing that it would be in the interest of justice not to push the parties through a "full dress trial". At the same time, the order records the Court's concern that road rage "can assume dangerous proportions and at times even fatal ramifications". The public element of such conduct — the risk to bystanders and other road users, and the burden cast on the investigating machinery — does not disappear with a private compromise.
The Court therefore quashed both FIRs and all proceedings arising from them, subject to conditions: each petitioner was directed to deposit Rs. 20,000 with the Bharat Ke Veer fund within one week, and to file the receipts before the trial court by 30 September 2026. In default, the proceedings would continue against the petitioner who failed to pay.
How a compromise quashing proceeds
The takeaway
Cross-FIRs from spontaneous altercations are frequent in Delhi, and this order reflects the pragmatic course the High Court routinely adopts: where both sides have registered cases against each other and have since made peace, insisting on two parallel trials benefits no one. But litigants should not read compromise as amnesty. Courts increasingly attach monetary conditions to mark the public wrong, and a default in complying with those conditions revives the prosecution in full.
This article summarises a judicial order for general information. It is not legal advice, and the outcome of any quashing petition depends on the nature of the offence and the facts of the particular case.
Frequently Asked Questions
Can every FIR be quashed if the parties settle?
No. The inherent power is exercised mainly where the dispute is predominantly private or personal — matrimonial discord, monetary disputes, minor scuffles — and a settlement makes conviction remote. Heinous and serious offences, or crimes with a strong public character, are ordinarily not quashed merely because the complainant has compromised.
Under which provision are FIRs quashed after 1 July 2024?
For cases governed by the new codes, the High Court exercises its inherent power under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which corresponds to the former Section 482 of the Code of Criminal Procedure, 1973. The settled principles developed under Section 482 continue to guide the exercise of this power.
Why do courts impose costs while quashing on compromise?
Costs mark the public dimension of the offence. Even when the private parties have made peace, conduct such as road rage endangers others and consumes police and judicial time. Directing a payment — here Rs. 20,000 per petitioner to the Bharat Ke Veer fund — allows closure while conveying that the conduct is not cost-free.
What happens if the costs are not paid?
Conditional quashing means the relief operates only on compliance. In this matter the Court required receipts to be filed before the trial court by 30 September 2026, failing which proceedings would continue against the defaulting petitioners. Non-payment therefore revives the prosecution.