Cyber fraud involve systemic public detriment - FIR can not be quashed on basis of compromise

Punjab and Haryana High Court Dismisses Petition to Quash Cyber Fraud FIR Court Emphasizes Public Interest and Systemic Trust Over Private Settlements in Cyber Fraud Cases

The Punjab and Haryana High Court, presided over by Mr. Justice Sumeet Goel, has rejected a petition filed by Badri Mandal and others seeking to quash an FIR related to cyber fraud on the basis of a private compromise. The FIR, registered on June 27, 2025, under various sections of the Bharatiya Nagarik Suraksha Sanhita, 2023, pertains to unauthorized transactions amounting to approximately Rs. 14.83 lakhs from the complainant's bank account.

The Court was presented with a compromise deed dated September 20, 2025, wherein the complainant expressed no further grievance, and both parties agreed to withdraw the legal proceedings. However, the Court held that cyber fraud cases involve systemic public detriment and erosion of trust in the digital ecosystem, making them unsuitable for quashing based solely on private settlements.

Justice Goel underscored the broader societal implications of cyber fraud, stating that these crimes not only affect individual financial losses but also impact public confidence in digital transactions. The judgment emphasized that while private settlements may resolve interpersonal disputes, they do not address the cascading institutional injury caused by such frauds. The Court highlighted the need for a meticulous judicial appraisal of facts to distinguish between actual cyber fraud and cases where allegations are artificially invoked.

The decision aligns with precedents set by the Supreme Court, which have consistently held that heinous or serious offences, particularly those affecting public order and societal welfare, should not be quashed merely on the basis of compromise. The Court's ruling thus reinforces the importance of maintaining the integrity of the justice system and upholding public trust in digital financial transactions.

Bottom Line:

Cyber fraud cases - Quashing of FIR on basis of compromise/settlement between parties - Held, cyber fraud cases involve systemic public detriment and erosion of trust in digital ecosystem - Inherent jurisdiction of High Court under Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023, ought not to be exercised for quashing FIRs pertaining to cyber fraud solely on basis of private settlement.

Statutory provision(s): Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528

Badri Mandal v. State of Haryana, (Punjab And Haryana) : Law Finder Doc Id # 2806962