The Madhya Pradesh High Court has refused anticipatory bail to a man accused of allegedly threatening and harassing a GST officer after his application for GST registration was rejected. The Court observed that the allegations, supported by material collected during the investigation, were serious enough to deny the discretionary relief of anticipatory bail.
Background of the Case
The case arose from an application filed by Pradeep Kumar Jatav under Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), seeking anticipatory bail in Crime No. 394/2026 registered at Police Station Kotwali, Shivpuri, for offences under Sections 308(2) and 308(6) of the Bharatiya Nyaya Sanhita (BNS).
According to the prosecution, the complainant, an Assistant Commissioner of GST posted at Shivpuri, had rejected the applicant's GST registration request in July 2025 because it lacked the required identity proof and other mandatory documents. Despite being informed of the deficiencies, the applicant allegedly continued insisting that the registration be granted.
The prosecution further alleged that after the rejection, the applicant repeatedly visited the complainant's office, introduced himself as a journalist, and later began sending WhatsApp messages containing allegedly false and defamatory material. Several Facebook posts were also allegedly published against the complainant and her family over the following months. The FIR further alleged that the applicant demanded ₹1 crore to stop publishing such material and threatened to implicate the complainant and her family in false criminal cases if the demand was not met.
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Applicant's Stand
Counsel for the applicant argued that the allegations were false and motivated. It was submitted that the case was primarily based on documentary and electronic evidence that had already been seized, making custodial interrogation unnecessary.
The defence also claimed that the applicant, who described himself as a journalist, had only attempted to expose alleged unlawful acts of the complainant and had been falsely implicated. It was further argued that, being a permanent resident of Shivpuri, he was neither likely to abscond nor interfere with the investigation.
Court's Observation
After examining the case diary, Justice Rajesh Kumar Gupta found that the accusations were of a serious nature.
The Court observed,
"The allegations against the present applicant are serious in nature."
It further noted that the material available in the case diary, including certain WhatsApp chats, indicated elements of alleged threats and an attempt to obtain unlawful gain from the complainant.
The bench also remarked that the prosecution alleged the applicant had attempted to intimidate a public servant and tarnish her reputation through posts on different social media platforms after his work was not carried out.
Decision
Considering the seriousness of the allegations, the manner in which the alleged acts were committed, and the material available during investigation, the High Court declined to exercise its discretion in favour of the applicant.
Dismissing the plea, the Court held that the applicant was not entitled to anticipatory bail, and the application was accordingly rejected.
Case Details:
Case Title: Pradeep Kumar Jatav v. State of Madhya Pradesh
Case Number: Misc. Criminal Case No. 28051 of 2026
Judge: Justice Rajesh Kumar Gupta
Decision Date: 30 June 2026
