MP High Court Refuses To Quash FIR Against Journalist For Allegedly Extorting Money From Doctor

The Madhya Pradesh High Court has dismissed the petition of a journalist seeking to quash the FIR concerning extortion allegations levelled by a private allopathy doctor, observing that the investigation was at a nascent stage and the journalist's prior criminal record makes quashing the proceedings premature or improper. 

The bench of Justice Rajesh Kumar Gupta observed;

"Since the investigation is still at a nascent stage and the Petitioner's criminal antecedents (and those of his associates) have been brought on record, it would be premature and improper to quash the proceedings". 

A petition was filed by a Journalist seeking to quash an FIR registered in District Bhind alleging extortion (Section 308) of BNS. 

Per the facts of the case, Dr Harmendra Singh, on May 2, 2025, submitted a complaint alleging that on April 30, 2025, the petitioner, along with another journalist (Pritam Singh), approached him. The complaint alleged that he held a BAMS degree but was practising allopathy in an unregistered clinic. The petitioner, along with another, allegedly demanded a monthly payment of ₹5,000. Upon refusal, they threatened the complainant to publish a daily report until the clinic is forced to close. 

The complainant further alleged that on May 1, 2025, the petitioner sent him an article regarding the clinic through WhatsApp. The FIR noted a news report of May 1, 2025, published in Bejod Ratna newspaper and authored by the petitioner, detailing the illegal operation of complinaant's clinic. 

The counsel for the petitioner argued that he had recently reported on illegal sand mafia activities in the Chambal River, which were being carried out by the sand mafia in connivance with local police. Displeased with the same, SP Yadav had invited the petitioner to have tea with him, wherein he, along with other journalist were made to strip down to their undergarments and was physically assaulted. 

The counsel for the petitioner argued that many such incidents have occured recently, due to which the State Press Club had issued a statement on May 3, 2025, demanding action against the police officers. 

The counsel for the respondents conteded that the petitioner allegedly used his position as a journalist to extort and blackmail the people. 

The court first reiterated that if information discloses the commission of a cognizable offence, the existence of a personal grudge or ulterior motive of the complainant/police is not sufficient ground to stifle legitimate investigation at its threshold. 

The court noted that the allegations levelled against the petition are disputed questions of fact and therefore cannot be examined by the High Court, but are to be adjudicated by the Trial Court. 

Further, regarding the allegations of custodial misconduct levelled by the journalist, the court noted that

"The existence of a parallel dispute between the Petitioner and the local police does not grant the Petitioner immunity from investigation into a specific, third-party complaint lodged by a private medical practitioner". 

Thus, noting that the investigation was at a nascent stage and the petitioner had criminal antecedents, the court deemed it premature to quash the proceedings. 

Case Title: Shashikant Jatav v State of Madhya Pradesh, WP-34590-2025

For Petitioner: Advocate Sameer Kumar Shrivastava

For State: Additional Advocate General Ankur Modi

For SP Yadav: Senior Advocate M P S Raghuvanshi with Advocate Mohammad Amir Khan

Click here to read/download the Order