Madhya Pradesh High Court
Atul Agrawal vs The State Of Madhya Pradesh on 25 February, 2026
NEUTRAL CITATION NO. 2026:MPHC-JBP:17589
1 MCRC-17118-2023
IN THE HIGH COURT OF MADHYA PRADESH
AT JABALPUR
BEFORE
HON'BLE SHRI JUSTICE HIMANSHU JOSHI
ON THE 25th OF FEBRUARY, 2026
MISC. CRIMINAL CASE No. 17118 of 2023
ATUL AGRAWAL
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Surendra Singh - Senior Advocate along with Shri Kapil Pathak -
Advocate for the applicant.
Shri C.S. Upadhyay - PL for the respondent-State.
ORDER
The present petition has been filed under Section 482 of the Code of Criminal Procedure seeking quashment of FIR bearing Crime No.192/2023 dated 03.04.2023 registered at Police Station Gopalganj, District Sagar for offences punishable under Sections 182, 193, 211, 386, 506, 109 of the IPC and Sections 3(1)(r), 3(1)(d), 3(2)(v), 3(2)(va) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act.
2. As per the prosecution case, on 31.01.2023 and 02.04.2023, the applicant approached respondent No. 2 and asked her to lodge a false complaint of rape against Amit Jain and Ajay Lambardar. It is alleged that he promised to pay her a sum of Rs. 2,00,000/- for filing such a complaint. The applicant is further alleged to have taken away her mobile phone and Aadhaar card, stating that the same would be returned after the lodging of the Signature Not Verified Signed by: MANOJ NAIR Signing time: 10-03-2026 15:07:09 NEUTRAL CITATION NO. 2026:MPHC-JBP:17589 2 MCRC-17118-2023 report. It is also alleged that when respondent No. 2 expressed her unwillingness to lodge the false complaint, the applicant threatened her over the telephone. Consequently, respondent No. 2 lodged the impugned FIR against the applicant.
3. Learned counsel for the applicant submits that the applicant is a Journalist-cum-Social Worker and had earlier made complaints regarding illegal mining by M/s Sagar Stoned Company, of which Amit Jain is the proprietor. It is contended that the Collector, Sagar, by order dated 31.03.2023, found the allegations of illegal mining to be true and thereafter imposed penalty of Rs.12,15,195/- by order dated 06.04.2023. According to the applicant, due to this action, Amit Jain has maliciously instigated respondent No.2 to lodge a false FIR against him on 03.04.2023. It is further contended that even if the allegations in the FIR are taken at their face value, no offence is made out. The allegations are stated to be absurd and inherently improbable and the criminal proceedings are alleged to be maliciously instituted with an ulterior motive to wreak vengeance. In support of his contention, learned counsel for the applicant has placed reliance on the decision of the Apex Court in the case of Isaac Isanga Musumba and Ors. vs. STate of Maharashtra and Ors. [(2014) 15 SCC 357].
4. Per contra, learned counsel for the State opposed the prayer and submitted that the FIR discloses cognizable offences and specific allegations have been made against the applicant. It is submitted that investigation is at a nascent stage and this Court should not exercise inherent powers to stifle legitimate prosecution.
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5. Heard the submissions and perused the material available on record.
6. The scope of interference under Section 482 Cr.P.C. for quashment of FIR is well settled by the Hon'ble Supreme Court in State of Haryana v. Bhajan Lal, { AIR 1992 SC 604} wherein illustrative categories were laid down where quashment may be justified. It is equally settled that at the stage of quashment, the Court is required to consider whether the allegations made in the FIR, taken at their face value and accepted in their entirety, prima facie constitute the offence alleged. The Court is not expected to embark upon an appreciation of evidence or adjudicate disputed questions of fact.
7. In the present case, the FIR contains specific allegations that the applicant induced respondent No.2 to lodge a false rape case against two named persons in consideration of money; that he took her mobile phone and Aadhaar card; and that he threatened her when she declined. Such allegations, if taken at their face value, prima facie attract ingredients of offences punishable under Sections 182, 193, 211, 386, 506 and 109 IPC. The allegations also refer to offences under the SC/ST (Prevention of Atrocities) Act, which require investigation in accordance with law.
8. The principal defence of the applicant is that the FIR is a counterblast to the action taken against Amit Jain for illegal mining pursuant to the applicant's complaint. However, the plea of mala fide or personal vendetta by itself is not sufficient ground to quash criminal proceedings when the FIR otherwise discloses commission of cognizable offences. Even assuming that there was prior enmity, that by itself cannot be a ground to discard the allegations at the threshold. It is well settled that where factual Signature Not Verified Signed by: MANOJ NAIR Signing time: 10-03-2026 15:07:09 NEUTRAL CITATION NO. 2026:MPHC-JBP:17589 4 MCRC-17118-2023 foundations are laid in the FIR, the truthfulness or otherwise of the allegations is a matter of trial.
9. The contention that the allegations are inherently improbable cannot be accepted at this stage. Whether the respondent No.2 was pressurized, whether any promise of money was made, whether threats were extended, and whether the FIR has been lodged at the instance of a third party are all matters requiring investigation and appreciation of evidence. This Court, while exercising inherent jurisdiction, cannot conduct a mini-trial or examine the defence material relied upon by the applicant.
10. The orders passed by the Collector regarding illegal mining may at best indicate prior dispute between the parties, but they do not render the allegations in the FIR so absurd or inherently improbable as to fall within the categories enumerated in Bhajan Lal (supra). The allegations, on their plain reading, cannot be said to be so patently absurd that no prudent person can reach a conclusion that an offence is made out. The inherent powers under Section 482 Cr.P.C. are to be exercised sparingly, with circumspection and in the rarest of rare cases. The present case does not fall within such exceptional categories.
11. In view of the aforesaid discussion, this Court is of the considered opinion that the FIR discloses commission of cognizable offences and the matter requires appreciation of evidence by the trial Court. No case for interference under Section 482 Cr.P.C. is made out.
12. The judgment as relied upon by the learned Senior counsel for the applicant is of no assistance to the applicant.
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13. Accordingly, the petition stands dismissed.
14. It is, however, clarified that any observations made herein are only for the purpose of deciding the present petition and shall not prejudice either party during trial.
(HIMANSHU JOSHI) JUDGE mn Signature Not Verified Signed by: MANOJ NAIR Signing time: 10-03-2026 15:07:09