Delhi High Court Quashes Cross-FIRs After Road-Rage Parties Settle; Imposes ₹20,000 Cost on Each Petitioner as Deterrent Against Future Violence and Misconduct
Delhi High Court Quashes Cross-FIRs After Road-Rage Dispute Is Settled; Imposes ₹20,000 Cost on Each Petitioner as Deterrent
Facts
Two connected petitions came before the Delhi High Court seeking quashing of cross-FIR Nos. 43/2026 and 24/2026, both registered at Police Station Sarita Vihar.
The FIRs concerned offences under Sections 115(2), 126(2), 351(2) and 3(5) of the Bharatiya Nyaya Sanhita (BNS) and arose from a road-rage dispute between the private parties. Both sides subsequently entered into a compromise and approached the High Court seeking termination of the criminal proceedings.
In the connected petition, the Court also allowed an application to implead Amit Chadha as a party and took the amended memo of parties on record.
Statements of the parties regarding the compromise had already been recorded before the concerned Joint Registrar. When the matters were taken up, the private parties personally appeared before the Court and confirmed that all disputes had been settled and that they did not wish to continue prosecuting the cross-FIRs.
Issues
- Whether the cross-FIRs arising from a road-rage incident could be quashed on the basis of a settlement between the private parties.
- Whether continuing the criminal prosecution despite the compromise would serve any useful purpose.
- Whether the serious nature and potentially dangerous consequences of road-rage violence warranted a deterrent condition despite settlement.
- Whether quashing should therefore be made conditional upon payment of costs by the petitioners.
Petitioners’ Arguments
The petitioners sought quashing of the respective cross-FIRs on the basis that the underlying dispute had been amicably settled between all private parties.
The parties had already recorded their statements concerning the settlement before the Joint Registrar and personally reaffirmed before the High Court that their disputes stood resolved.
They specifically informed the Court that they did not wish to continue the criminal prosecutions arising from either FIR.
Respondent’s Arguments
The State did not oppose quashing of the cross-FIRs in principle.
However, the learned APP submitted that considering the nature of the offences and the fact that the incident involved road rage, some deterrent cost should be imposed upon the petitioners.
Beyond seeking such a deterrent measure, the State expressed no objection to quashing the criminal proceedings.
Analysis of the Law
The Court approached the matter by balancing two considerations.
First, the criminal dispute was essentially between private parties who had voluntarily settled their differences and no longer wished to prosecute one another.
After personally interacting with the parties in Court, Justice Girish Kathpalia was satisfied about the settlement and concluded that it would not serve the interests of justice to compel them to undergo a “full dress trial” despite resolution of their dispute.
Second, the Court was unwilling to treat road-rage violence as an entirely private or inconsequential matter merely because the parties had subsequently compromised.
The Court specifically recognised that road rage can assume dangerous proportions and may even result in fatal consequences. Accordingly, while settlement justified quashing, a deterrent measure remained necessary to discourage the parties from resorting to similar violence in future.
Thus, the Court adopted a middle course: it terminated the criminal proceedings in view of the settlement but imposed monetary costs as a condition of quashing.
Precedent Analysis
The judgment does not cite or discuss any judicial precedent concerning quashing of criminal proceedings on the basis of compromise.
The decision was based primarily upon:
- the settlement between the private parties;
- their statements already recorded before the Joint Registrar;
- their personal confirmation before the High Court;
- the State’s lack of substantive objection to quashing; and
- the Court’s concern regarding the dangerous consequences of road-rage violence.
Accordingly, the Court exercised its quashing jurisdiction on the specific facts before it rather than undertaking a detailed precedent-based analysis.
Court’s Reasoning
The Court personally interacted with the private parties and was satisfied that their disputes had been genuinely resolved.
Since neither side wished to continue prosecuting the cross-cases, forcing them to undergo a complete criminal trial would serve little practical purpose.
At the same time, Justice Girish Kathpalia emphasised that the incident involved road rage, which could not be lightly disregarded because such incidents may escalate into serious or even fatal violence.
The prosecution’s suggestion that some deterrent measure should accompany the quashing therefore had merit.
The Court consequently decided that the appropriate balance was to quash both FIRs while imposing costs of ₹20,000 upon each petitioner. The amount was directed to be deposited online with Bharat Ke Veer within one week.
Significantly, the Court made the quashing effectively conditional upon compliance. Each petitioner was required to file the cost receipt before the Trial Court, where the matter was stated to be listed on 30 September 2026.
If any petitioner failed to deposit the amount and file the receipt, the criminal trial against that defaulting petitioner/accused would continue.
Conclusion
The Delhi High Court allowed both petitions and quashed FIR Nos. 43/2026 and 24/2026, registered at Police Station Sarita Vihar under Sections 115(2), 126(2), 351(2) and 3(5) BNS, along with all consequential proceedings.
However, considering the road-rage nature of the dispute, the Court imposed a deterrent cost of ₹20,000 on each petitioner, payable to Bharat Ke Veer within one week.
The petitioners were required to produce the payment receipts before the Trial Court. In case of default by any petitioner, the trial against that particular petitioner/accused would continue.
Case Details
Case: Ankur Rawat & Anr. v. State of NCT of Delhi & Anr., connected with Purushotem Chadha v. State of NCT of Delhi & Ors.
Court: Delhi High Court
Case Numbers: CRL.M.C. 2142/2026 & CRL.M.A. 8841/2026; CRL.M.C. 2296/2026, CRL.M.A. 24038/2026 & CRL.M.A. 9366/2026
Judge: Justice Girish Kathpalia
Date: 07 August 2026
Result: Cross-FIRs quashed on compromise, subject to each petitioner depositing ₹20,000 with Bharat Ke Veer within one week; trial to continue against any defaulting petitioner.
