Can a Petition under Section 482 CrPC for Quashing FIR Be Withdrawn Without Adjudication on Merits? (Precedential Implications of Dismissal as Withdrawn)

A petition seeking quashing of FIR under Section 482 CrPC was withdrawn by the petitioner before any arguments on merits, with the High Court allowing its dismissal as withdrawn. The judgment upholds procedural norms and has no binding impact on questions of law, reinforcing that such withdrawn matters hold no precedential value.

 

Summary

Category Data
Case Name CRM-M/44776/2025 of MANJINDER SINGH Vs STATE OF PUNJAB AND ANOTHER
CNR PHHC011281812025
Date of Registration 13-08-2025
Decision Date 28-10-2025
Disposal Nature DISMISSED (as withdrawn)
Judgment Author MR. JUSTICE RAJESH BHARDWAJ
Court High Court of Punjab and Haryana
Bench Single Judge (MR. JUSTICE RAJESH BHARDWAJ)
Precedent Value None (dismissed as withdrawn; not a precedent on merits)
Type of Law Criminal Procedure
Facts as Summarised by the Court The petition under Section 482 CrPC sought quashing of FIR No. 1153 dated 04.09.2023 registered under Sections 420, 467, 468, 471 IPC, 1886 at Police Station Majitha, District Amritsar. The petitioner’s counsel sought leave to withdraw the petition, and the court allowed withdrawal without adjudicating the merits.

Practical Impact

Category Impact
Binding On None (no binding authority created)
Persuasive For None (no persuasive authority; not on merits)
Follows Standard procedure for withdrawal of petitions

What’s New / What Lawyers Should Note

  • Dismissal as withdrawn of quashing petitions under Section 482 CrPC does not settle any question of law or fact.
  • Such orders carry no precedential value and may not be cited as authority for legal propositions.
  • The court’s acceptance of petition withdrawal re-emphasizes the procedural right of parties to withdraw petitions before merits are decided.

Summary of Legal Reasoning

  • The petitioner, through counsel, sought permission to withdraw the criminal miscellaneous petition filed under Section 482 CrPC.
  • The court granted leave to withdraw and accordingly dismissed the petition as withdrawn.
  • No substantive discussion or adjudication on legal issues or merits was undertaken.

Arguments by the Parties

Petitioner

  • Requested permission to withdraw the petition seeking quashing of FIR.

Respondent

  • No arguments or submissions recorded in the judgment.

Factual Background

The petitioner filed a petition before the High Court under Section 482 CrPC for quashing FIR No. 1153 dated 04.09.2023 registered at Police Station Majitha, District Amritsar, under Sections 420, 467, 468, and 471 IPC, 1886. Before entering into arguments on the merits, counsel for the petitioner sought and was granted permission to withdraw the petition.

Statutory Analysis

  • Section 482 of the Code of Criminal Procedure, 1973 cited as the basis for the quashing petition.
  • No interpretation, construction, or application of statutory provisions was undertaken since the matter was withdrawn without hearing.

Dissenting / Concurring Opinion Summary

None. The order was passed by a single judge with no concurring or dissenting opinion.

Procedural Innovations

None. The dismissal as withdrawn follows established procedural norms without any new procedural direction or innovation.

Alert Indicators

  • Precedent Followed – Procedural norms regarding withdrawal of petitions followed; no substantive law determined.

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