[Cites 14, Cited by 0]
Madhya Pradesh High Court
Manjeet Dahal vs The State Of Madhya Pradesh on 11 February, 2026
Author: Milind Ramesh Phadke
Bench: Milind Ramesh Phadke
NEUTRAL CITATION NO. 2026:MPHC-GWL:6012
1 MCRC-31939-2024
IN THE HIGH COURT OF MADHYA PRADESH
AT GWALIOR
BEFORE
HON'BLE SHRI JUSTICE MILIND RAMESH PHADKE
ON THE 11th OF FEBRUARY, 2026
MISC. CRIMINAL CASE No. 31939 of 2024
MANJEET DAHAL
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Ankur Maheshwari - Advocate for the petitioner.
Ms. Kalpana Parmar - Public Prosecutor for the State.
ORDER
By invoking the inherent jurisdiction of this Court under Section 528
of the Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section
482 of the Code of Criminal Procedure, 1973), the petitioner seeks
quashment of FIR registered as Crime No.224 of 2019 at Police Station
Cyber Cell, District Gwalior (M.P.) for the offences punishable under
Sections 420, 467, 468, 471, 120-B and 34 of the Indian Penal Code, 1860
read with Sections 66-C and 66-D of the Information Technology Act, 2000.
Along with the petition, I.A. Nos.15112 of 2024 and 15113 of 2024
have been filed by the parties stating that the dispute has been amicably
resolved and that they do not wish to pursue the matter further. In
compliance with order dated 31.07.2024, the Principal Registrar has verified
the compromise and reported that the same has been entered into voluntarily,
without any threat, inducement or coercion.
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Learned counsel for the petitioner submits that in view of the
compromise, continuation of the criminal proceedings would amount to
abuse of the process of law and no fruitful purpose would be served by
allowing the trial to proceed. It is thus prayed that this Court, in exercise of
its inherent powers, may quash the FIR and all consequential proceedings.
Per contra, learned Public Prosecutor for the State opposes the prayer
and submits that the offences alleged are serious, non-compoundable in
nature and involve allegations of cheating, forgery of valuable security and
cyber impersonation. Such offences, it is contended, have serious societal
ramifications and cannot be permitted to be quashed merely on the basis of
compromise between private parties.
Heard counsel for the parties and perused the record.
This Court, in Deepanshu Morya vs. State of M.P. & Others (M.Cr.C.
No.46678 of 2025 decided on 25.11.2025), while dealing with a similar
prayer under Section 528 of the BNSS for quashment of FIR on the basis of
compromise in a case involving cyber fraud and offences under the BNS and
IT Act, has held that economic offences and cyber crimes affecting public
trust and institutional integrity cannot be treated as purely private disputes. It
was observed that such offences have wider societal impact and therefore do
not fall within the category of cases where inherent powers can be exercised
merely on the basis of compromise. Relevant extract of the aforesaid reads as
under:
4. If the FIR which has been lodged against the present
applicants is considered, then it is clear that as per prosecution
story, a complaint was lodged by the then Secretary of
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Ramakrishna Mission Ashram, Thatipur, Gwalior namely Swami
Supradiptanand alleging that on 17 March 2025, he received a
WhatsApp call from a person impersonating a police officer from
Nashik. The caller informed him that an FIR had been registered
against him under the Money Laundering Act and showed details
of a bank account opened in his name with transactions of
approximately Rs.20 crore. Under the guise of investigation
and threat of arrest, the caller obtained confidential financial
details of the ashram and induced the complainant to transfer a
total sum of Rs.2,52,99,000 to several accounts between 17 March
and 11 April 2025. When the amount was not refunded and the
caller became untraceable, the complainant realized that he
had been cheated through cyber fraud by unknown persons who
impersonated police officials and used forged documents. Initially,
the FIR was registered against unknown person and during
investigation, the applicant was made accused in the present case.
5. It is not disputed that the FIR emanates from an allegation of
cyber fraud wherein the complainant was deceived by unknown
persons impersonating police officials and induced to transfer a
huge sum of public charitable funds belonging to an institution of
repute, namely, the Ramkrishna Mission Ashram, Gwalior. During
investigation, the present applicant was implicated on the basis
of evidentiary material collected by the Investigating Agency.
Although the parties have filed a joint compromise and its
voluntariness has been verified by the Principal Registrar, the
nature of the allegations and the magnitude of the fraud are such
that they transcend the realm of a purely personal or private
dispute.
6. The Hon'ble Supreme Court in Gian Singh (supra) and
Narinder Singh (supra), has held that subject to the gravity of the
offence, the proceedings can be quashed on the basis of
compromise, but in the present case, if the allegations made
against the present applicants are taken into consideration, then it
appears that they are serious in nature and are not private in nature
and have serious impact on the society.
7. The Hon'ble Apex Court in the case of Parbatbhai Aahir v.
State of Gujarat, (2017) 9 SCC 641 has categorically observed that
economic offences involving public money or institutional trust
cannot be quashed merely on the ground of settlement between
some of the parties. It has further been held that offences which
are purely personal in nature and do not affect the society can
be quashed on the basis of compromise, whereas offences which
have serious social implications or constitute economic offences
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and crimes against the public at large cannot be permitted to be
compromised. It is settled that while the High Court has inherent
powers to quash criminal proceedings under Section 482 of the
Code of Criminal Procedure (now Section 528 of the BNSS), such
powers are to be exercised sparingly and with great caution.
8. The offence alleged in the present case relates to a large-scale
cyber fraud involving cheating, impersonation and unlawful
diversion of substantial funds belonging to a charitable
organization. The nature of the allegations demonstrates that the
acts complained of are not confined to any private dispute between
individuals but constitute serious offences affecting the
community at large. Cyber fraud and digital impersonation have
emerged as significant threats in the modern digital era, with far-
reaching consequences for public trust in online financial
transactions. Offences of this nature cause not only direct financial
loss to the affected institution but also inflict wider reputational
harm, thereby undermining the credibility of charitable
organizations that function for public welfare. Most importantly,
such offences corrode societal confidence in the security of digital
systems and create an atmosphere of mistrust among the
public. Given the broader societal ramifications, the alleged acts
cannot be characterized as issues of a purely personal or private
nature capable of resolution through compromise. Cyber offences,
by their very nature, transcend individual interests and implicate
collective concerns relating to economic security,
institutional integrity, and public trust in digital governance.
Therefore, permitting quashing of criminal proceedings solely on
the basis of a compromise with one of the office bearers of the
institution would undermine the object and efficacy of criminal
law, weaken the deterrent framework against sophisticated digital
crimes, and run counter to the larger public interest as well as the
fundamental principles of justice.
9. Accordingly, in cases of this nature where the alleged offence
strikes at the financial integrity of public-oriented institutions and
poses a threat to societal trust, the criminal proceedings cannot be
quashed on the ground of private settlement, even if a compromise
has been reached between the accused and a representative of the
organization.
10. In view of the settled legal position and considering the
gravity, magnitude, and societal impact of the alleged offence, this
Court is of the considered opinion that the present case does not
fall within the permissible category wherein criminal proceedings
may be quashed on the basis of a compromise. Accordingly, the
application filed under Section 528 of the Bharatiya Nagarik
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Suraksha Sanhita (corresponding to Section 482 of the Code
of Criminal Procedure) seeking quashing of FIR No. 10/2025 and
the consequential proceedings is hereby dismissed.
11. The trial shall proceed in accordance with law and without
being influenced by this order.
In view of the aforesaid well-reasoned order passed by this Court in
Deepanshu Morya vs. State of M.P. & Others ( supra), and having regard to
the settled principles governing the exercise of inherent jurisdiction under
Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding
to Section 482 of the Code of Criminal Procedure, 1973), this Court proceeds
to examine the present matter.
In the instant case, the petitioner seeks quashment of FIR registered as
Crime No.224 of 2019 at Police Station Cyber Cell, District Gwalior for the
offences punishable under Sections 420, 467, 468, 471, 120-B, 34 of the
Indian Penal Code, 1860 read with Sections 66-C and 66-D of the
Information Technology Act, 2000 on the basis of compromise arrived at
between the parties.
The allegations, as reflected from the FIR and the material available
on record, pertain to offences involving cheating, forgery of valuable
security, use of forged documents and cyber-related impersonation. The
nature of such accusations prima facie discloses commission of economic
and cyber offences which cannot be termed as merely personal disputes inter
se the parties. The offences alleged carry serious penal consequences and
have wider ramifications affecting public faith in digital transactions and
financial integrity.
Though the compromise between the petitioner and respondent No.2
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has been duly verified by the Principal Registrar and appears to have been
entered into voluntarily without coercion or undue influence, the same by
itself cannot be a decisive ground for quashing criminal proceedings in cases
involving serious and non-compoundable offences.
The Hon'ble Supreme Court in Gian Singh v. State of Punjab, (2012)
10 SCC 303; Narinder Singh v. State of Punjab, (2014) 6 SCC 466; and in
Parbatbhai Aahir v. State of Gujarat reported in (2017) 9 SCC 641 has
consistently held that while the High Court possesses wide inherent powers
to quash criminal proceedings to secure the ends of justice, such powers are
to be exercised with caution. It has been categorically observed that offences
which are serious in nature, involve moral turpitude, economic fraud,
forgery, or have a serious impact on society, cannot be quashed merely on
the basis of a private compromise between the parties.
The present case involves allegations under Sections 467 and 468 IPC
relating to forgery of valuable security and forged documents, which are
grave offences affecting public confidence in documentation and financial
systems. Similarly, offences under Sections 66-C and 66-D of the IT Act
pertain to identity theft and cheating by personation using computer
resources offences which have assumed alarming proportions in the digital
era and affect society at large.
This Court is of the considered view that the alleged acts, by their very
nature, transcend the boundaries of a private dispute and fall within the
category of offences having serious societal and economic implications.
Permitting quashment of such proceedings solely on the basis of compromise
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would dilute the deterrent effect of criminal law in matters concerning cyber
fraud and forgery, and would not be in consonance with the larger public
interest.
Accordingly, in light of the gravity and nature of the allegations, and
in view of the settled legal position, this Court is not inclined to exercise its
inherent powers under Section 528 of the Bharatiya Nagarik Suraksha
Sanhita, 2023 for quashing of FIR No.224 of 2019 and the consequential
proceedings on the basis of compromise.
The petition, being devoid of merit, is hereby dismissed. It is,
however, clarified that the observations made herein are confined to
adjudication of the present petition and shall not prejudice the trial of the
case on merits.
The trial Court shall proceed in accordance with law, uninfluenced by
any observations made in this order.
(MILIND RAMESH PHADKE)
JUDGE
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