In a significant judgment that reinforces the sanctity of criminal justice, the Punjab and Haryana High Court has refused to quash an FIR in a rash and negligent driving case that resulted in a man's death, despite a financial settlement between the accused and the victim's family.
Court Upholds Judicial Integrity Over Private Settlements
Justice Sumeet Goel delivered the landmark ruling on November 20, emphasizing that a victim cannot be treated as a forgotten entity once criminal proceedings have commenced. The court observed that using the high court's inherent powers to quash serious criminal cases based solely on financial compromises would effectively privatize criminal liability and portray penal absolution as a purchasable commodity.
The case originated from a June 2022 incident in Moga, where Satnam Singh allegedly knocked down Gurjit Singh with his vehicle. Gurjit succumbed to his injuries while being transported to the hospital. Following investigation, the Moga court convicted Satnam under Section 304A (causing death by negligence) of the Indian Penal Code.
Financial Settlement Fails to Sway Court
After the conviction, the parties reached a compromise where Satnam agreed to pay Rs 13 lakh to the victim's father, Harbhajan Singh. Based on this settlement, Satnam approached the high court seeking quashing of the FIR and subsequent proceedings, including his conviction.
Advocate Kamaldep Singh Sidhu, representing the accused, argued that the FIR was filed due to a misunderstanding that had now been resolved. He contended that continuing criminal proceedings would serve no useful purpose and that quashing them would ensure peace between the parties. The victim's father, through his counsel Kirandeep Kaur, supported the compromise and raised no objections to quashing the case.
State's Opposition and Court's Reasoning
However, Additional Advocate General Amit Kumar Goyal strongly opposed the plea, arguing that in offenses under Section 304A resulting in death, the deceased is the real victim, and any settlement with family members cannot absolve the offender.
Justice Goel's judgment elaborated several crucial principles that guided the decision:
- Compromising grave offenses risks undermining public confidence in the justice delivery system
- Such practices suggest that serious public wrongs can be nullified based on an accused person's financial capacity
- The severity of crime and penal consequences must remain insulated from private financial arrangements
- Law must balance competing interests of the accused and the victim while serving larger societal interests
The court invoked the principles of victimology, noting that in fatal offenses, the person who dies remains the primary victim, and surviving family members cannot fully represent that victim's interests for settlement purposes.
Broader Implications for Criminal Justice
Justice Goel emphasized that the criminal justice system's purpose extends beyond safeguarding accused persons' rights to include effective vindication of victims' rights. The ruling stated that practices involving pecuniary considerations in serious criminal cases can damage societal psyche by suggesting the justice system is available for commodification.
The court quoted Latin maxims to reinforce that the high court's inherent powers are meant to do real and substantial justice, not to undermine the rule of law. The judgment serves as a crucial reminder that Article 21 of the Constitution embraces both the accused's rights and the victim's interests, along with broader community concerns, which cannot be lightly separated.
This landmark decision establishes an important precedent against the trend of quashing serious criminal cases based solely on financial settlements between parties, reinforcing that justice cannot be bought or sold.
