Panju Giri Goswami vs The State Of Madhya Pradesh on 29 April, 2026

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    Madhya Pradesh High Court

    Panju Giri Goswami vs The State Of Madhya Pradesh on 29 April, 2026

              NEUTRAL CITATION NO. 2026:MPHC-JBP:33533
    
    
    
    
                                                                      1                    MCRC-11972-2026
                                    IN     THE      HIGH COURT OF MADHYA PRADESH
                                                          AT JABALPUR
                                                               BEFORE
                                                HON'BLE SHRI JUSTICE HIMANSHU JOSHI
                                                         ON THE 29th OF APRIL, 2026
                                                 MISC. CRIMINAL CASE No. 11972 of 2026
                                                       PANJU GIRI GOSWAMI
                                                              Versus
                                            THE STATE OF MADHYA PRADESH AND OTHERS
                               Appearance:
    
    
                                         Shri Manish Datt - Senior Advocate with Shri Eshaan Datt -
                               Advocate for the petitioner.
                                         Shri Abhijeet Awasthi - Deputy Advocate General for respondent
                               no.1/State.
    
                                    Heard on         :   16.04.2026
    
                                    Pronounced on    :   29.04.2026
    
                                                                          ORDER
    

    This petition is filed under Section 528 of the Bharatiya Nagarik
    Suraksha Sanhita, 2023 seeking quashment of FIR bearing Crime

    No.473/2025 registered at Police Station Lakhanwara, District Seoni (M.P.)
    for offences punishable under Sections 310(2), 126(2), 140(3), 61(2) and
    238(b) of the Bharatiya Nyaya Sanhita, 2023, along with charge sheet and all
    consequential criminal proceedings arising therefrom.

    SPONSORED

    2. Case of prosecution is that on 09.10.2025, one Sohan Lal Parmar, a
    resident of Jalna, Maharashtra, lodged information at Police Station Kotwali,

    Signature Not Verified
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    HIMANSHU SHARMA
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    2 MCRC-11972-2026
    Seoni alleging that his associate Mukhtar and driver Irfan Pathan had been
    intercepted and robbed by personnel of Seoni Police. It was alleged that out
    of a total sum of Rs. 2,96,50,000 being transported in a vehicle, an amount of
    Rs.1,45,00,000 had been unlawfully taken by police officials. Upon receipt
    of the complaint, the matter was escalated to senior police official, who
    ordered a preliminary inquiry. Shri Ayush Gupta, Additional Superintendent
    of Police, was appointed as the Inquiry Officer to ascertain the veracity of
    the allegations.

    3. During the course of inquiry, it was revealed that the complainant and
    his associates were allegedly transporting a large sum of cash, suspected to
    b e hawala money, in a Creta vehicle. The inquiry further disclosed that
    information regarding such transportation had reached the then SDOP, Pooja

    Pandey (co-accused). Acting upon the said information, Pooja Pandey
    allegedly conducted a raid along with a team of police officials including
    ASI Arpit Bhairam, Head Constables Ravindra Uike, Makhan Singh Inwati,
    and Rajesh Janghela, Constables Jagdish Yadav, Yogendra Chaurasiya,
    Subhash Sadaphal, Kedar Singh, Neeraj Rajpoot, and driver Reetesh Verma.
    It is alleged that after intercepting the vehicle and recovering the cash
    amount, the raiding party attempted to negotiate a settlement with the
    occupants of the vehicle, demanding 75% of the recovered amount.
    Subsequently, a sum of Rs.1,45,00,000 was allegedly taken by SDOP Pooja
    Pandey and the individuals Mukhtar and Irfan were released.

    4. The inquiry report further states that the present petitioner who was
    informer of police, has been implicated on the allegation that he passed on

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    HIMANSHU SHARMA
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    prior information to co-accused Pramod Soni who was constable in Crime
    Branch, Jabalpur, who in turn informed co-accused Pankaj Mishra, DSP who
    further informed main accused Pooja Pandey. The implication of the
    petitioner is primarily based on call detail records (CDR) indicating
    telephonic contact between the petitioner, and co-accused persons. The
    Inquiry Officer, relying primarily on mobile phone call detail records and
    Mobile Forensic Analysis Report, concluded that present petitioner, Pankaj
    Mishra, and constable Pramod Soni were in contact before and after the
    alleged incident with the raiding party, and inferred their complicity in the
    alleged offence. During the course of investigation, an amount of
    Rs.1,45,00,000/- was recovered from the possession of co-accused Pooja
    Pandey and ASI Arpit Bhairam. Additionally, one Virendra Dixit, brother-in-
    law of Pooja Pandey, was also implicated in the alleged offence.

    5. On the basis of the aforesaid inquiry report, the police registered FIR
    bearing Crime No.473/2025 at Police Station Lakhanwara, District Seoni,
    and after investigation, filed the charge-sheet against all the accused persons,
    including the present petitioner.

    6. Learned counsel for the petitioner submits that the petitioner was not a
    member of the raiding party and had no role whatsoever in the alleged
    interception or recovery of money. The entire case against the petitioner rests
    solely on call detail records, which only indicate that calls were made, but do
    not disclose the contents or nature of communication. He further submitted
    that no call transcripts, recordings, or electronic evidence have been

    produced to establish any conspiracy or illegal agreement. Upon receiving

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    information from one Sanwla Ram on 08.10.2025, the petitioner
    immediately passed such information to constable Pramod Soni, who passed
    such information further. There is no evidence on record to show that the
    petitioner is in any way connected in the said case. There is no evidence of
    pre-meeting of minds, which is a sine qua non for establishing the offence of
    criminal conspiracy. The CDR details merely give rise to suspicion and
    cannot be equated with proof to make out the charges under alleged
    offences. He further submitted that the case squarely falls within the category
    of abuse of process of law, warranting interference by this Court. In support
    of his contention, he has relied upon the following pronouncements :

    1. Central Bureau of Investigation, Hydrabad Vs. K. Narayana Rao ,
    reported in (2012) 9 SCC 512 .

    2. Saju Vs. State of Kerala , reported in (2001) 1 SCC 378 .

    3. Shyam Gupta and other Vs. State , reported in 203 SCC OnLine
    Del 1490.

    4. Kunwarpal Vs. State through Sho, P.S. Sepcial Cell, reported in
    2024 SCC OnLine Del 1163 .

    5. Esher Singh Vs. State of A.P. reported in (2004) 11 SCC 585 .

    7. On the other side, counsel for the State opposed the petition by
    submitting that the preliminary objection of State is regarding maitainability
    of present petition as the petitioner has an efficacious and specific statutory
    remedy available before the learned Trial Court by way of seeking discharge
    at the appropriate stage of the proceedings and the petitioner instead of
    availing the remedy of discharge, has prematurely invoked the jurisdiction
    under Section 528 BNSS. On merits, the counsel for the State argued that the

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    HIMANSHU SHARMA
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    material collected during investigation and filed along with the charge-sheet
    clearly discloses the commission of cognizable offences and the involvement
    of the present petitioner as an active conspirator. It is settled law that at the
    stage of quashment, the Court is only required to examine whether a prima
    facie case is made out and not to meticulously appreciate evidence or
    conduct a mini-trial. The petitioner is not an innocent bystander, but a
    keylink in the chain of conspiracy, who facilitated the commission of the
    offence by passing on sensitive information with the malafide intention. On
    08.10.2025, the petitioner forwarded an information to constable Pramod
    Soni regarding transportation of a huge amount of cash who communicated
    the said information to co-accused Pankaj Mishra. The said Pankaj Mishra
    further transmitted the information to the main accused Pooja Pandey,
    leading to the illegal interception and misappropriation of money. Thus, the
    petitioner acted as the originator of the information chain, without which the
    offence could not have been committed. He further argued that the
    prosecution relies upon Call Detail Records (CDR) and their forensic
    analysis, which reveal around 25 telephonic conversations between the
    petitioner and Pramod Soni, out of which 7 calls were made after the
    incident. There is existence of continuous communication before, during, and
    even after the commission of the offence. These repeated and timed
    communications are not random or innocuous, but form a consistent pattern
    pointing towards coordinated action.

    8. It is further submitted that conspiracy is generally hatched in secrecy,
    and therefore, direct evidence is rarely available. The same can be
    established through circumstantial evidence, including conduct and

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    communication patterns. The petitioner continued to remain in contact with
    co-accused even after the offence was committed, which is wholly
    inconsistent with his claim of bonafide conduct. It is further argued that
    petitioner’s defence cannot be considered at this stage and cannot be
    adjudicated in proceedings under Section 528 BNSS. It is well settled that
    quashing of FIR and charge sheet is an exceptional remedy, to be exercised
    sparingly and the present case does not satisfy the parameters laid down for
    quashment. He prays for dismissal of petition. In support of his
    contentions, learned Deputy Advocate General has placed reliance on the
    following judgments rendered by Hon’ble The Supreme Court :-

    (i) Neeharika Infrastructure vs. State of Maharashtra [2021(19)SCC
    401].

    (ii) Ajay Kumar Das vs. State of Jharkhand [2011(12) SCC 319].

    (iii) CBI vs. Arvind Khanna [2019(10) SCC 666].

    (iv) State of Odisha vs. Pratima Mohanti [2022(16) SCC 703].

    (v) CBI vs. Aryan Singh [2023(18) SCC 399].

    (vi) Kaptan Singh vs. State of U.P. [2021 (9) SCC 35].

    9. Heard the learned counsel for parties and perused the charge-sheet.

    10. Upon hearing learned counsel for the parties and perusing the material
    available on record, this Court is called upon to consider the preliminary
    objection raised by the respondent/State regarding the maintainability of the
    present petition under Section 528 of the Bharatiya Nagarik Suraksha
    Sanhita, 2023. The principal contention of the respondent is that the
    petitioner has an efficacious alternative remedy of seeking discharge before
    the learned Trial Court and, therefore, the present petition is premature and

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    HIMANSHU SHARMA
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    not maintainable. This submission, though attractive at first blush, cannot be
    accepted as universally correct. It is well settled that the existence of an
    alternative remedy does not operate as an absolute bar to the exercise of
    jurisdiction under Section 528 BNSS, particularly if the petitioner is able to
    demonstrate that continuation of the proceedings would amount to an abuse
    of the process of law or would result in a miscarriage of justice. The
    jurisdiction under the said provision is wide and is intended, inter alia, to
    secure the ends of justice.

    11. In the present case, the foundational allegation against the petitioner is
    that he had passed on certain information regarding a vehicle allegedly
    carrying suspicious cash to co-accused Pramod Soni who passed the same to
    Pankaj Mishra who in turn passed such information to Pooja Pandey. Beyond
    this, there is no direct material indicating his participation in the alleged
    interception, negotiation, or misappropriation of money. Upon a careful and
    comprehensive perusal of the material placed on record, particularly the
    statements of the complainant Sohan Lal Parmar, Mukhtar Khan, driver-
    Irfan, Aman Gurnani, co-accused Pooja Pandey, and other police personnel
    including Arpit Bhairam, Neeraj Rajput, Subhash Sadafal, Makhan Singh
    Inwati, Jagdish Yadav, Yogendra Chaurasia, Reetesh Verma, Kedar Singh,
    Rajesh Janghela, Ajay Rai, as well as the statements of Deepak Mishra,
    Additional Superintendent of Police, Seoni, and Pankaj Mishra, this Court
    finds that there is no incriminating material whatsoever against the present
    petitioner. None of the witnesses, including the complainant and his
    associates, have made any allegation against the petitioner. Significantly,
    there is no material to show that the petitioner was in any manner in contact

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    with the complainant party. No call detail or communication has been
    brought on record indicating any interaction between the petitioner and the
    complainant or his associates at any point of time. The statements of the
    complainant and other witnesses consistently attribute all overt acts to co-
    accused Pooja Pandey and the raiding party. There is no allegation that the
    petitioner was present at the spot, handled the cash, or derived any pecuniary
    benefit. It is further evident that the petitioner was not a member of the
    raiding party and had no direct role in the interception of the vehicle,
    recovery of the amount, or the alleged subsequent acts attributed to the co-
    accused persons.

    12. The entire prosecution case against the petitioner rests on a singular
    allegation that he was in constant telephonic contact with co-accused Pankaj
    Mishra, Pramod Soni and other co-accused persons, thereby suggesting his
    involvement in a criminal conspiracy. The prosecution seeks to implicate the
    petitioner primarily on the basis of call detail records and mobile forensic
    analysis indicating frequent communication between the petitioner and co-
    accused. However, the investigation itself reveals that the petitioner had
    merely forwarded information received from one other person to Pramod
    Soni. Beyond this, no overt act has been attributed to him.

    13. After hearing learned counsel for the parties and perusing the case
    diary and charge-sheet, no overt act has been attributed to him in execution
    of the alleged crime. The prosecution relies heavily on CDRs. However,
    CDRs merely establish that calls were exchanged; same do not disclose the
    contents of conversation. No transcripts, voice recordings, or electronic
    messages have been placed on record. Mere telephonic contact, without

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    anything more, cannot establish criminal conspiracy.
    1 4 . Further, for an offence of conspiracy, there must be cogent material
    indicating prior agreement or meeting of minds. In the present, case no such
    agreement is demonstrated. No communication directly linking the petitioner
    with the main accused Pooja Pandey has been established and the
    prosecution case is based on inference and suspicion, not concrete evidence.
    There is no evidence to indicate that the petitioner had any knowledge of, or
    participation in, the alleged illegal retention or misappropriation of the
    recovered amount. A crucial aspect of merits consideration is that the
    prosecution relies solely on call detail records. There is no call recording, no
    transcript of conversations, and no electronic chats or messages seized or
    produced before the Court. In absence of the contents of communication, the
    mere existence of calls without any substantive content demonstrating a prior
    meeting of minds or agreement to commit an illegal act, howsoever frequent
    cannot by itself constitute criminal conspiracy under Section 61(2) of the
    Bharatiya Nyaya Sanhita, 2023. Telephonic contact, in the nature of official
    communication between police officials and informer, cannot be elevated to
    incriminating evidence without any supporting material indicating unlawful
    intent or agreement. Further, the investigation report dated 13.10.2025 itself
    proposed registration of FIR primarily against the main accused Pooja
    Pandey and other members of the raiding party. Even the principal accused
    has not made a single statement implicating the present petitioner in the
    alleged offence. This omission assumes significance and weakens the
    prosecution case against the petitioner.

    15. As regards Sections 140(3), 310(2) and 126(2) BNS, which relate to

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    kidnapping, dacoity and wrongful restraint, respectively, there is not even a
    whisper in the entire prosecution material attributing any overt act to the
    petitioner in the alleged commission of these offences. The gravamen of
    these allegations pertains to the acts allegedly committed at the spot by the
    raiding party. The petitioner’s role, even as per the prosecution, is too remote
    and disconnected to attract these provisions. In absence of any corroborative
    material, mere existence of call records, without more, is insufficient to infer
    complicity or establish any nexus between the petitioner and the alleged
    offence.

    16. The invocation of Section 238(b) BNS on the basis of alleged deletion
    of electronic data is equally unsustainable. There is no material to show that
    such deletion was with the intent to cause disappearance of evidence of an
    offence. The allegation regarding deletion of the video is misconceived. The
    said video, as reflected from the material on record, was merely
    informational in nature, intended to demonstrate general techniques used in
    concealing or detecting illicit activities, particularly in cases involving
    hawala transactions. It cannot, by any stretch of imagination, be construed as
    having been shared with any criminal intent or in furtherance of the alleged
    offence. Even otherwise, its circulation, if at all, appears to be in good faith
    and for operational awareness in the course of duty, rather than to facilitate
    any illegal activity. In absence of any corroborative material linking the said
    video to the commission of the alleged offence, no adverse inference can be
    drawn against the petitioner.

    17. There is also no recovery effected from the petitioner, nor any evidence
    of wrongful gain. Even if the entire prosecution case is accepted as it stands,

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    the act of the petitioner in passing on information regarding suspicious
    movement of cash cannot, by any stretch of imagination, be said to fall
    outside the ambit of his citizen duties or informer duties. In the absence of
    any material indicating dishonest intention or active participation in the
    alleged misappropriation, the continuation of criminal proceedings against
    the petitioner would be unjustified.

    18. The implication of the petitioner thus appears to be founded merely on
    suspicion arising out of call detail records. It is a settled principle of criminal
    jurisprudence that suspicion, however strong, cannot take the place of proof.
    While suspicion may justify investigation or interrogation, it cannot form the
    basis of a charge-sheet in absence of cogent, credible, and legally admissible
    evidence. It is well settled that while exercising inherent jurisdiction under
    Section 482 of the Code of Criminal Procedure/528 of BNSS, this Court
    does not undertake a meticulous appreciation of evidence, but is nevertheless
    duty-bound to examine whether the material collected during investigation
    discloses the commission of any offence or raises a grave suspicion against
    the accused. The Hon’ble Supreme Court in Prafulla Kumar Samal reported
    in (1979) 3 SCC 4 has held that where the material gives rise only to some
    suspicion and not grave suspicion, the accused is entitled to be discharged,
    and continuation of proceedings would be unjustified. The relevant para is
    quoted hereinunder :

    “10. Thus, on a consideration of the authorities mentioned
    above, the following principles emerge:

    (1) That the Judge while considering the question of

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    framing the charges under Section 227 of the Code has the
    undoubted power to sift and weigh the evidence for the limited
    purpose of finding out whether or not a prima facie case against
    the accused has been made out.

    (2) Where the materials placed before the Court disclose
    grave suspicion against the accused which has not been properly
    explained the Court will be fully justified in framing a charge and
    proceeding with the trial.

    (3) The test to determine a prima facie case would naturally
    depend upon the facts of each case and it is difficult to lay down a
    rule of universal application. By and large however if two views
    are equally possible and the Judge is satisfied that the evidence
    produced before him while giving rise to some suspicion but not
    grave suspicion against the accused, he will be fully within his
    right to discharge the accused.

    (4) That in exercising his jurisdiction under Section 227 of
    the Code the Judge which under the present Code is a senior and
    experienced court cannot act merely as a Post Office or a

    mouthpiece of the prosecution, but has to consider the broad
    probabilities of the case, the total effect of the evidence and the
    documents produced before the Court, any basic infirmities
    appearing in the case and so on. This however does not mean that
    the Judge should make a roving enquiry into the pros and cons of
    the matter and weigh the evidence as if he was conducting a trial.”

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    19. The principle laid down by the Hon’ble Supreme Court in Prafulla
    Kumar Samal (supra), though rendered in the context of framing of charge,
    has a clear and persuasive bearing while examining the legality of criminal
    proceedings at the threshold. The Court therein held that where the material
    on record gives rise only to some suspicion and not grave suspicion, the
    accused ought not to be compelled to face trial. By necessary analogy, this
    principle informs the exercise of inherent jurisdiction under Section 482 of
    the Code of Criminal Procedure/528 of BNSS as well, inasmuch as
    continuation of proceedings founded merely on conjectural or weak
    suspicion would amount to an abuse of process. It is equally well settled that
    where the allegations and material, even if taken at face value, fail to disclose
    the essential ingredients of an offence or do not rise above mere suspicion,
    the Court would be justified in interdicting the proceedings at the inception.

    20. In the present case, the prosecution primarily relies upon alleged
    WhatsApp calls and telephonic communications between the parties.
    However, it is an admitted position that there is no transcript, recording, or
    legally admissible electronic evidence placed on record to establish the
    contents of such conversations. At best, the material produced only indicates
    that certain calls were exchanged, which merely proves the factum of
    communication and not the substance thereof. In absence of any
    authenticated record in terms of the requirements of electronic evidence, the
    same cannot be treated as substantive material capable of establishing the
    ingredients of the alleged offence.

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    21. In the present case, the material on record fails to disclose any meeting
    of minds, prior agreement, or concerted action on the part of the petitioner so
    as to constitute an offence of conspiracy or any other alleged offence. The
    essential ingredients of the offences invoked are conspicuously absent qua
    the petitioner.

    22. Thus, the entire edifice of the prosecution case rests on conjectures and
    unverified inferences, which do not travel beyond the realm of mere
    suspicion. The material on record fails to disclose any proximate or direct
    nexus between the petitioner and the alleged offence, nor does it give rise to
    the degree of grave suspicion as contemplated in Prafulla Kumar Samal
    (supra).

    23. The Hon’ble Supreme Court in State of Haryana v. Bhajan Lal reported
    i n 1992 Supp (1) SCC 335 has authoritatively laid down the parameters
    governing the exercise of inherent powers for quashing of FIR and criminal
    proceedings. The Court held that where the allegations made in the FIR or
    the material collected during investigation, even if taken at their face value
    and accepted in entirety, do not prima facie constitute any offence or make
    out a case against the accused, such proceedings deserve to be quashed. It
    was further held that where the allegations are so absurd and inherently
    improbable that no prudent person can ever reach a just conclusion that there
    is sufficient ground for proceeding, or where the proceedings are manifestly
    attended with mala fide and instituted with an ulterior motive, the High
    Court would be justified in exercising its jurisdiction to prevent abuse of the
    process of law. The said judgment thus clearly enunciates that criminal

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    prosecution cannot be permitted to continue on the basis of mere suspicion,
    conjectures, or unsupported allegations. The relevant para is quoted herein
    under :

    “102. In the backdrop of the interpretation of the various
    relevant provisions of the Code under Chapter XIV and of the
    principles of law enunciated by this Court in a series of decisions
    relating to the exercise of the extraordinary power under Article
    226
    or the inherent powers under Section 482 of the Code which
    we have extracted and reproduced above, we have given the
    following categories of cases by way of illustration wherein such
    power could be exercised either to prevent abuse of the process of
    any court or otherwise to secure the ends of justice, though it may
    not be possible to lay down any precise, clearly defined and
    sufficiently channelised and inflexible guidelines or rigid formulae
    and to give an exhaustive list of myriad kinds of cases wherein
    such power should be exercised.

    (1) Where the allegations made in the first information
    report or the complaint, even if they are taken at their face value
    and accepted in their entirety do not prima facie constitute any
    offence or make out a case against the accused.

    (2) Where the allegations in the first information report and
    other materials, if any, accompanying the FIR do not disclose a
    cognizable offence, justifying an investigation by police officers

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    under Section 156(1) of the Code except under an order of a
    Magistrate within the purview of Section 155(2) of the Code.

    (3) Where the uncontroverted allegations made in the FIR or
    complaint and the evidence collected in support of the same do not
    disclose the commission of any offence and make out a case
    against the accused.

    (4) Where, the allegations in the FIR do not constitute a
    cognizable offence but constitute only a non-cognizable offence,
    no investigation is permitted by a police officer without an order
    of a Magistrate as contemplated under Section 155(2) of the Code.

    (5) Where the allegations made in the FIR or complaint are
    so absurd and inherently improbable on the basis of which no
    prudent person can ever reach a just conclusion that there is
    sufficient ground for proceeding against the accused.

    (6) Where there is an express legal bar engrafted in any of
    the provisions of the Code or the concerned Act (under which a
    criminal proceeding is instituted) to the institution and continuance
    of the proceedings and/or where there is a specific provision in the
    Code or the concerned Act, providing efficacious redress for the
    grievance of the aggrieved party.

    (7) Where a criminal proceeding is manifestly attended with
    mala fide and/or where the proceeding is maliciously instituted
    with an ulterior motive for wreaking vengeance on the accused
    and with a view to spite him due to private and personal grudge.”

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    24. In view of the foregoing analysis, this Court is of the considered
    opinion that the continuation of criminal proceedings against the present
    petitioner is wholly unwarranted and amounts to abuse of the process of law.
    The allegations against the petitioner are not supported by any substantive
    evidence and are based merely on conjectures and inferences drawn from call
    detail records, which by themselves are insufficient to establish criminal
    liability.

    25. Accordingly, this Court is of the considered opinion that the essential
    ingredients of offences punishable under Sections 310(2), 126(2), 140(3),
    61(2) and 238(b) of the Bharatiya Nyaya Sanhita, 2023 are not made out
    against the present petitioner and the petition deserves to be and is hereby
    allowed. The charge-sheet and all consequential criminal proceedings arising
    out of Crime No. 473/2025 registered at Police Station Lakhanwara, District
    Seoni (M.P.), insofar as they relate to the present petitioner, are hereby
    quashed. The petitioner is discharged from above mentioned charges.

    (HIMANSHU JOSHI)
    JUDGE

    rv

    Signature Not Verified
    Signed by: REENA
    HIMANSHU SHARMA
    Signing time: 29-04-2026
    18:56:20



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