The Orissa High Court on Wednesday brought a quiet but decisive end to a criminal dispute that had travelled from a police station in Bhubaneswar to the mediation centre and finally back to the courtroom. Allowing a petition filed under its inherent powers, the court quashed an FIR and all related proceedings after the parties confirmed that the matter had been amicably settled through mediation.
The order was passed by Justice Savitri Ratho, who underlined how effective mediation can save judicial time and provide practical relief to both sides when supported by proper infrastructure and trained mediators.
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Background of the Case
The case arose from Laxmisagar Police Station Case No. 567 of 2024, registered for alleged offences under Sections 420 (cheating), 294 (obscene acts) and 506 (criminal intimidation) of the Indian Penal Code. The FIR named Sarfaraz Khan, Noor Alam Khan, and Subhasish Pradhan as accused, along with two others.
Following the registration of the case, the accused approached the High Court seeking protection and quashing of proceedings. In an earlier hearing in November 2024, the court granted interim protection and referred the dispute to mediation, noting that the allegations stemmed from a financial disagreement between private parties.
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The mediation process proved decisive. A mediator’s report dated 16 December 2024 confirmed that the parties had reached a settlement. Under the agreement, the accused undertook to pay ₹18 lakh to the informant, Pabitra Kumar Mohapatra, by January 10, 2025.
Counsel for the petitioners later informed the court that the full amount had been paid and that a formal settlement agreement was executed on 21 January 2025. The informant, represented by his advocate, also confirmed in open court that he had received the money and no longer wished to pursue the criminal case.
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Court’s Observations
While hearing the matter, the bench referred to the Supreme Court’s observations on the growing importance of mediation as an alternative dispute resolution mechanism. Emphasising the present case as a practical example, the court observed that mediation succeeded because of three key factors: availability of infrastructure, presence of a trained mediator, and willingness of parties to resolve the dispute.
“The informant has got back his money, the accused persons do not have to face criminal proceedings, and valuable time of the court has been saved,” the bench noted, describing the outcome as a “win-win situation for all concerned.”
The Decision
After perusing the FIR, the mediation report, and the joint affidavit filed by both sides, the High Court held that no useful purpose would be served by continuing the criminal proceedings.
Accordingly, the court quashed the FIR and all proceedings arising from Laxmisagar P.S. Case No. 567 of 2024, pending before the Judicial Magistrate First Class (IV), Bhubaneswar. The criminal miscellaneous case was disposed of, bringing the dispute to a formal close.
Case Title: Sarfaraz Khan & Ors. v. State of Orissa & Anr.
Case No.: CRLMC No. 5379 of 2025
Case Type: Criminal Miscellaneous (Quashing of FIR)
Decision Date: 18 December 2025
