Can an FIR be withdrawn in Pakistan? Compromise, cancellation and quashing

Why you cannot simply take an FIR back

Many people think the person who lodged the FIR can tear it up by giving the police an affidavit. The law does not work that way. In a 2018 judgment the Supreme Court explained that once an FIR is registered, a criminal case comes into existence and keeps its number until the matter is finally decided (PLD 2018 SC 595, para 27). The police then investigate on their own. Their final report "is to be based upon the actual facts discovered during the investigation irrespective of the version of the incident advanced by the first informant" (PLD 2018 SC 595, para 27).

Section 345 of the Criminal Procedure Code is the only door for a compromise, and it closes every other door.

“(6) The composition of an offence under this section shall have the effect of an acquittal of the accused with whom the offence has been compounded. (7) No offence shall be compounded, except as provided by this section.”

Criminal Procedure Code 1898 · Section 345, Compounding offence

Offences you can settle without the court's permission

Section 345(1) has a table of smaller offences that the victim can compound directly. A few of the common ones:

• Wrongful confinementSection 342 PPC; compounded by the person confined (s.345(1)).
• Assault or criminal forceSections 352, 355 and 358 PPC (s.345(1)).
• Criminal trespass and house-trespassSections 447 and 448 PPC; compounded by the person in possession (s.345(1)).
• Dishonoured chequeSection 489-F PPC; compounded by the person in whose favour the cheque was issued (s.345(1)).
• Defamation, insult and intimidationSections 500, 504 and 506 PPC, but not intimidation punishable with seven years (s.345(1)).

Offences you can settle only with the court's permission

Section 345(2) lists serious offences that can be compounded only "with the permission of the Court before which any prosecution for such offence is pending". They include qatl-i-amd (s.302), attempt to commit qatl-i-amd (s.324), most kinds of hurt (s.337-A to 337-N), cheating (ss.417 to 420), dishonest misappropriation (s.403), a second marriage during a spouse's lifetime (s.494) and insulting the modesty of a woman (s.509). The table names who can compound: for murder, the heirs of the victim; for hurt, the injured person.

• Step 1: Check the section in the FIRFind it in the section 345(1) or 345(2) table. If it is in neither, a compromise cannot end the case (s.345(7)).
• Step 2: Put the compromise before the courtIn 2026 SCMR 480 all the heirs filed affidavits and recorded statements before the trial court (para 3).
• Step 3: The court checks it is genuineThe trial court must be satisfied: in 2016 SCMR 1190 the Supreme Court sent the case back so that the trial court, "after verifying the genuineness of the compromise to its satisfaction shall accept the same and acquit the appellants" (2016 SCMR 1190, para 9).
• Step 4: Acquittal followsA lawful compounding has the effect of an acquittal (s.345(6)). It can happen even while an appeal is pending, with the appeal court's leave (s.345(5)).
• Step 5: Do not expect to undo itThe Supreme Court held that "once a compromise has been reached between the deceased's legal heirs and the accused, it cannot be withdrawn later" (2026 SCMR 480, para 4).

“(2) The offences punishable under the sections of the Pakistan Penal Code specified in the first two columns of the table next following may, with the permission of the Court before which any prosecution for such offence is pending, be compounded by the persons mentioned in the third column of that table”

Criminal Procedure Code 1898 · Section 345, Compounding offence

Murder cases: forgiveness, sulh and the honour-killing limit

In qatl-i-amd the heirs may forgive the killer without compensation (afw, section 309 PPC) or settle for agreed compensation (sulh, section 310 PPC). Section 310 forbids giving a woman in marriage as part of the settlement.

Forgiveness does not always mean freedom. Under section 311, the court can still punish where not all heirs forgive, or where the principle of fasad-fil-arz applies, which includes a killing in the name of honour. In an honour killing the killer himself cannot act as an heir (section 305 PPC).

The Supreme Court has read section 311 narrowly: "the provisions of Section 311 of the P.P.C. are applicable only in cases where the sentence of Qisas has been awarded to the accused" (2026 SCMR 480, para 6). Even so, in that case the heirs' forgiveness of a man who had killed two people over suspected illicit relations did not set him free: his conviction stayed, and his death sentences became life imprisonment (2026 SCMR 480, para 10).

“Where all the wali do not waive or compound the right of qisas, or if the principle of fasad-fil-arz is attracted, the court may, having regard to the facts and circumstances of the case, punish an offender against whom the right of qisas has been waived or compounded with death or imprisonment for life or imprisonment of either description for a term of which may extend to fourteen years as ta'zir: Provided that if the offence has been committed in the name or on the pretext of honour, the punishment shall be imprisonment for life.”

PPC · Section 311, Ta'zir after waiver or compounding of right of qisas in qatl-i-amd

“(1) In the case of qatl-i-amd, an adult sane wali may, at any time on accepting badal-i-sulh, compound his right of qisas”

PPC · Section 310, Compounding of qisas (Sulh) (صلح) in qatl-i-amd

When the police find the FIR false

If the investigation shows no offence, the police say so in their report under section 173 CrPC, which goes to the Magistrate. In 2016 SCMR 2176 the Supreme Court granted bail where the police had already concluded the allegation was false and "upon completion of the investigation a report has already been submitted seeking cancellation of the FIR" (2016 SCMR 2176, para 2). A complainant who no longer supports the case can tell the investigating officer the truth, but the decision on the report is not the complainant's.

“(1) Every investigation under this Chapter shall be completed without unnecessary delay, and, as soon as it is completed, the officer incharge of the police-station shall … forward to a Magistrate empowered to take cognizance of the offence on a police-report, a report in the form prescribed by the Provincial Government”

Criminal Procedure Code 1898 · Section 173, Report of police officer

Quashing: what the High Court can and cannot do

Section 561-A CrPC saves the High Court's inherent power. But the Supreme Court has said "a High Court has no power under section 561-A, Cr.P.C. to quash an FIR or an investigation proceeding" (PLD 2023 SC 265, para 4). That power covers court proceedings, and even then the High Court "should not ordinarily exercise its power under section 561-A, Cr.P.C. to make such order unless the accused person has first availed his remedy before the trial court under section 249-A or 265-K, Cr.P.C." (PLD 2023 SC 265, para 4).

Before the police report reaches court, an FIR registered without lawful authority can be challenged in a writ petition under Article 199 of the Constitution; in that case the High Court quashed an FIR that disclosed no cognizable offence (PLD 2023 SC 265, paras 4 to 10).

“Nothing in this Code shall be deemed to limit or affect the inherent power of the High Court to make such orders as may be necessary … to prevent abuse of the process of any Court or otherwise to secure the ends of justice.”

Criminal Procedure Code 1898 · Section 561-A, Saving of inherent power of High Court

What this does not mean

• This page does not cover anti-terrorism, NAB or other special-law offences; an anti-terrorism charge blocked a murder compromise in the courts below in 2016 SCMR 1190.
• A compromise ends the case only for the offence and the accused it covers; offences outside the section 345 tables stay on trial.
• Filing a false FIR is a separate matter; see our page on what to do about a false FIR.

Questions people ask

Sources

• Criminal Procedure Code 1898 · Section 345
  Compounding offence
• Criminal Procedure Code 1898 · Section 345
  Compounding offence
• PPC · Section 311
  Ta'zir after waiver or compounding of right of qisas in qatl-i-amd
• PPC · Section 310
  Compounding of qisas (Sulh) (صلح) in qatl-i-amd
• Criminal Procedure Code 1898 · Section 173
  Report of police officer
• Criminal Procedure Code 1898 · Section 561-A
  Saving of inherent power of High Court
• Mst. Sughran Bibi v. The State, PLD 2018 SC 595 (Supreme Court of Pakistan, 23 May 2018)
  An FIR starts a criminal case; the police report must rest on the facts found, not on the informant's version.
• Sanoober Khan v. The State, 2026 SCMR 480 (Supreme Court of Pakistan, 1 December 2025)
  A completed compromise cannot be withdrawn; s.311 PPC applies only where qisas was awarded; in an honour killing the death sentence became life imprisonment.
• Irfan v. Muhammad Yousaf, 2016 SCMR 1190 (Supreme Court of Pakistan, 6 April 2016)
  Trial court to verify the genuineness of a compromise in a murder case and then acquit.
• Haibat Khan v. The State, 2016 SCMR 2176 (Supreme Court of Pakistan, 4 February 2016)
  Bail granted where the police had found the allegation false and sought cancellation of the FIR.
• F.I.A. v. Syed Hamid Ali Shah, PLD 2023 SC 265 (Supreme Court of Pakistan, 6 February 2023)
  No quashing of an FIR under s.561-A CrPC; use 249-A/265-K first, or Article 199 against an unlawful FIR.

Every quote and section above is traced to the full judgment or statute text by an automatic check that runs on every update.