The Madhya Pradesh High Court has refused to quash an FIR against a practising advocate in a case involving allegations of repeated sexual assault by a former client. Justice Himanshu Joshi held that the existence of an advocate-client relationship does not, by itself, make such allegations impossible at the FIR stage.
Background of the Case
The petitioner, a practising advocate at Rewa, had represented the complainant in matrimonial proceedings. According to the petitioner, he later withdrew from the matter and issued a No Objection Certificate (NOC), following which the complainant began making complaints against him.
The FIR, registered as Crime No. 258/2025, followed a complaint alleging that the petitioner had pressured the complainant to compromise her matrimonial dispute, made obscene calls and subjected her to repeated sexual assault. The complaint referred to alleged incidents on December 26, 2024, January 4, 2025 and February 15, 2025, besides an allegation concerning pregnancy.
The advocate argued that the FIR was retaliatory and relied on earlier complaints, an Action Taken Report and proceedings before the National Commission for Scheduled Castes.
Court's Observation
The High Court noted that the FIR contained specific allegations, including dates, places and circumstances surrounding the alleged incidents. Whether those allegations were true, and whether they were supported by electronic or medical evidence, were matters for investigation, the Court said.
On the advocate-client relationship, the Court observed:
"The fact that the petitioner and respondent No.4 had an Advocate-client relationship does not, at the stage of registration of the FIR, render the allegations inherently impossible."
The Court further said that whether the allegations were an afterthought arising from a professional dispute or disclosed genuine criminal conduct could not be decided merely by examining the vakalatnama or matrimonial case records.
The Court also rejected the argument that earlier complaints allegedly found unsubstantiated established that the present FIR was false. It said each criminal allegation must be examined on its own facts and the material collected during investigation.
Decision
The Court held that the FIR did not fall within a category warranting interference at the threshold. It declined to quash the FIR or stop the criminal proceedings.
The Court also declined to grant blanket protection against coercive action and refused the request for a sweeping restraint on disclosure of the petitioner's name in the media.
It directed that the further investigation be conducted fairly and in accordance with law by the officer already entrusted with the matter.
Case Details:
Case Title: P.P. v. State of Madhya Pradesh & Others
Case Number: W.P. No. 24408 of 2025
Judge: Justice Himanshu Joshi
Decision Date: August 24, 2026
