The Court reaffirmed that once a cancellation report is filed before the trial court, petitions seeking quashing of the same FIR under Section 482 CrPC (or corresponding sections) become infructuous. Petitioners retain liberty to pursue remedies before the trial court. This disposition upholds established procedural law for criminal practice in the Punjab & Haryana region.
Summary
| Category | Data |
|---|---|
| Case Name | CRM-M/42207/2025 of JOGINDER PAWARIA Vs STATE OF HARYANA AND OTHERS |
| CNR | PHHC011216782025 |
| Date of Registration | 02-08-2025 |
| Decision Date | 10-09-2025 |
| Disposal Nature | DISPOSED OF |
| Judgment Author | MR. JUSTICE NAMIT KUMAR |
| Court | High Court of Punjab and Haryana |
| Bench | Single Judge Bench (HON’BLE MR. JUSTICE NAMIT KUMAR) |
| Precedent Value | Binding precedent within jurisdiction of Punjab & Haryana High Court |
| Type of Law | Criminal Procedural Law |
| Questions of Law | Whether a quashing petition under Section 482 CrPC becomes infructuous when a cancellation report is filed in trial court regarding the FIR in question. |
| Ratio Decidendi | Once the police have filed a cancellation report with respect to the FIR before the trial court, a petition before the High Court seeking quashing of that FIR becomes infructuous. The High Court will dispose such petitions as infructuous and grant the petitioner liberty to seek further remedies before the trial court as per law. |
| Facts as Summarised by the Court | The State counsel informed that the police had filed a cancellation report before the trial court related to the concerned FIR, therefore, the petition filed under Section 482 CrPC for quashing FIR and subsequent proceedings was rendered infructuous. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within Punjab & Haryana |
| Persuasive For | Other High Courts |
What’s New / What Lawyers Should Note
- Reaffirms that once a cancellation report regarding an FIR is filed before the trial court, parallel quashing petitions in the High Court become infructuous.
- Petitioners retain liberty to pursue any remedy regarding the cancellation report before the trial court as per law.
- Useful as a procedural precedent for lawyers handling quashing petitions where police have already recommended cancellation of the FIR.
- Lawyers should check the updated status of FIRs and related reports before continuing with quashing proceedings.
Summary of Legal Reasoning
- The State counsel informed the Court, based on instructions from the police, that a cancellation report pertaining to the FIR had been filed before the trial court.
- In view of this development, the High Court held that the petition seeking quashing of the FIR has become infructuous.
- The Court therefore disposed of the petition as having become infructuous.
- Liberty was expressly granted to the petitioner to pursue further remedies before the trial court, in accordance with law.
Arguments by the Parties
Petitioner:
- Filed petition seeking quashing of FIR under Section 482 CrPC.
Respondent (State):
- Stated on instructions from ASI Naresh Kumar that a cancellation report in respect of FIR No. 504 dated 06.11.2022 under Sections 406, 498-A, and 506 IPC has been filed before the learned trial court on 01.09.2025.
Factual Background
An FIR No. 504 dated 06.11.2022 under Sections 406, 498-A, and 506 IPC was registered at Police Station Sector 5, Panchkula. The petitioner approached the High Court under Section 482 CrPC seeking quashing of this FIR and subsequent proceedings. During the proceedings, the State informed the Court that a cancellation report had already been filed before the trial court.
Statutory Analysis
- The petition was filed under Section 482 CrPC for quashing of FIR.
- The FIR in question was registered under Sections 406, 498-A, and 506 IPC.
- Upon filing of a cancellation report by the police before the trial court regarding the said FIR, parallel quashing proceedings under Section 482 CrPC become infructuous as per established practice.
Procedural Innovations
No new procedural innovations or directions were issued in the judgment.
Alert Indicators
- ✔ Precedent Followed – The judgment affirms and applies existing procedural law regarding disposal of quashing petitions rendered infructuous by the filing of a cancellation report.