'Only Prima Facie Case Is Seen At Charge-Framing Stage': Allahabad HC Refuses Relief To Book Editor Accused Of Insulting Quran
Sparsh Upadhyay
9 April 2026 7:26 PM IST

The Allahabad High Court last week dismissed a criminal revision petition filed by a book editor seeking discharge in a case of allegedly publishing insulting words against Islam and the Quran.
Observing that, at the stage of framing charges, only a prima facie case is to be seen, a bench of Justice Subhash Chandra Sharma upheld a trial court order refusing to discharge Revisionist-Dr. Madan Gopal Sinha, the named editor of the book in question
Briefly put, a criminal case was registered under Section 153B, 295A IPC at a Police Station in District Ghazipur on the allegations that a book named 'Tankar Sawdhan Aage Yaha Visphotak' was published which contained insulting words against the religion of Islam.
The complaint alleged that the publication was circulated with the intent of disturbing religious harmony in society.
Several books were published and recovered by the police, and it was found that the present revisionist was the editor of those books, which were said to have been printed at the instance of accused Yashu Ji Maharaj, from a publication named Sanjay Pustak Bhandar.
In June 2025, the Additional Civil Judge and Judicial Magistrate in Ghazipur rejected the discharge plea filed by the revisionist under Section 239 CrPC.
Before the HC, his counsel argued that the investigating officer conducted no proper investigation and that the revisionist was falsely implicated merely because his name was printed as the book's editor.
On the other hand, the State argued that the printed contents contained insulting statements regarding the Quran and the material was likely to outrage the religious feelings of a class by insulting its religious beliefs.
After perusing the case diary and the trial court order, the High Court noted that the fact regarding the recovery of the books bearing the revisionist's name as editor was clearly mentioned in the case diary.
"Prima facie case was found to be established, as a result application for discharged moved by the revisionist was dismissed vide order dated 10.06.2025. There appears no illegality or impropriety in the order passed by the learned trial court but the revision being devoid of merit, is dismissed", the bench observed as it dismissed the plea.
Case title - Madan Gopal Sinha vs State of U.P. and Another 2026 LiveLaw (AB) 196
Case citation: 2026 LiveLaw (AB) 196
