Delhi High Court Quashes BNS FIR Over Stray Dog Feeding Dispute After Neighbours Settle Cross-Cases, Holds Quashing Needed to Restore Cordiality
Facts
The Delhi High Court was dealing with a petition filed by Manisha Rawat seeking quashing of FIR No. 0519/2024 dated 01.10.2024, registered at Police Station Shalimar Bagh for offences under Sections 126, 115(2) and 79 of the Bharatiya Nyaya Sanhita, 2023, corresponding to Sections 339, 323 and 509 IPC. The quashing was sought on the basis of an amicable settlement between the parties.
As per the FIR, the alleged incident took place on 01.10.2024 when the petitioner was feeding stray dogs. Her neighbour, respondent no. 2, allegedly tried to stop her, after which she allegedly became furious, threatened him, assaulted him, kicked him and abused him. The chargesheet had already been filed.
During the proceedings, the Court perused the Memorandum of Understanding dated 24.12.2025, which recorded the settlement between the parties. Respondent no. 2 appeared before the Court, was identified by his counsel and the Investigating Officer, and stated that he had settled the matter voluntarily and did not wish to pursue the FIR.
Issues
- Whether FIR No. 0519/2024 under Sections 126, 115(2) and 79 BNS could be quashed on the basis of settlement between the parties.
- Whether continuation of criminal proceedings would serve any useful purpose after the neighbour-dispute had been amicably resolved.
- Whether quashing was appropriate to restore cordiality between the parties, especially when a connected cross FIR also existed.
Petitioner’s Arguments
The petitioner sought quashing of the FIR on the ground that the dispute with respondent no. 2 had been amicably settled. She appeared in person before the Court.
The petitioner also assured and undertook that she would appear in the connected petition relating to cross FIR No. 518/2024 and make the requisite statement before the Court, as contemplated under the settlement.
Respondent’s Arguments
Respondent no. 2 appeared before the Court and confirmed that the matter had been amicably settled. He stated that he was no longer interested in pursuing the FIR and had entered into the settlement voluntarily, without pressure or coercion.
Respondent no. 2 further stated that a connected cross FIR, FIR No. 518/2024, had been registered against him on the basis of the petitioner’s complaint, and that as per the settlement, the petitioner had agreed to give her no-objection for quashing of that FIR also.
Analysis of the Law
The Court proceeded on the principle that where a criminal dispute is private in nature and the parties have voluntarily settled their differences, the High Court may exercise its inherent powers to quash the proceedings to secure the ends of justice.
The Court considered that the dispute arose between neighbours and that both sides had resolved their differences. Since the settlement also covered the connected cross FIR, the Court found that quashing would help maintain and restore cordial relations between the parties.
Precedent Analysis
The judgment does not expressly discuss any precedent. However, the Court applied the settled principle that criminal proceedings arising from private disputes may be quashed where the complainant voluntarily settles the matter and does not wish to continue prosecution.
The Court placed emphasis on the voluntary nature of the settlement, the presence and identification of respondent no. 2, and the broader need to facilitate cordiality between the parties.
Court’s Reasoning
The Court noted that respondent no. 2 had appeared in Court, had been duly identified, and had confirmed that he voluntarily entered into the settlement without any pressure or coercion.
The Court further noted that the dispute was connected with a cross FIR and that the parties had agreed to cooperate in quashing both matters. Keeping in mind the facts and the need to restore cordiality, the Court held that the proceedings deserved to be quashed in exercise of inherent powers.
Conclusion
The Delhi High Court quashed FIR No. 0519/2024 dated 01.10.2024 registered at Police Station Shalimar Bagh for offences under Sections 126, 115(2) and 79 BNS, along with all consequential proceedings. The Court directed that the original affidavits of the parties be submitted before the Trial Court within two weeks.
Case Details
Case: Manisha Rawat v. The State of NCT of Delhi & Anr.
Court: Delhi High Court
Case Number: CRL.M.C. 277/2026
Judge: Justice Manoj Jain
Date: 03 July 2026
Result: Petition allowed; FIR No. 0519/2024 under Sections 126, 115(2) and 79 BNS registered at Police Station Shalimar Bagh, along with consequential proceedings, quashed.
