The Madhya Pradesh High Court, Jabalpur, recently dismissed a criminal revision petition (CRR No. 126/2025) filed by Rohit Chaturvedi and Sheetal Singh Chouhan, personnel of the Railway Protection Force (RPF). The petitioners challenged the framing of charges against them under Sections 294, 379, 384, and 477 of the Indian Penal Code (IPC) by the IVth Additional Sessions Judge, Jabalpur. The judgment, delivered by Hon’ble Justice Devnarayan Mishra on August 4, 2025, reaffirmed key legal principles regarding the protection of public servants under Section 197 of the CrPC and Section 20(3) of the RPF Act.
Background of the Case
The case originated from a 2011 incident where the complainant, Smt. Saroj Vishwakarma, alleged that RPF personnel stopped her at Jabalpur Railway Station, accused her of traveling in a coach reserved for disabled persons, and forcibly took ₹5,000 from her bag. The complaint also stated that her railway ticket was torn, and she was abused. An FIR was registered under Sections 384, 341, 506, and 294 IPC.
The trial court framed charges against Rohit Chaturvedi under Sections 294 (obscenity), 379 (theft), 384 (extortion), and 477 (fraudulent cancellation/destruction of documents) IPC, and against Sheetal Singh Chouhan under Section 341 (wrongful restraint).
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The petitioners contended:
- Lack of Evidence: Charges were framed without proper evidence. The prosecution relied on a "false and fabricated" police report.
- Protection Under Section 197 CrPC: As public servants, they claimed immunity under Section 197 CrPC, which mandates prior sanction for prosecuting public servants for acts done in official capacity.
- Discrepancies in Complainant’s Testimony: The complainant’s school attendance register (obtained via RTI) showed her presence in Jabalpur on the alleged travel dates, contradicting her FIR claims.
- Legal Precedents: They cited judgments like Montek Singh vs. State of West Bengal and H.V. Nagaraju vs. State of Karnataka to argue that the trial court ignored protections under the RPF Act and CrPC.
Justice Mishra dismissed the revision, highlighting:
"At the stage of framing charges, the court is not bound to consider defence evidence. The veracity of documents like the school register must be tested during trial."
- Sanction Under Section 197 CrPC: The court noted the petitioners failed to raise this issue during initial proceedings, making it untenable at the revision stage.
- Defence Evidence: Citing State of Orissa vs. Debendra Nath Padhi, the court held that defence materials cannot be considered during charge framing.
- Value of Railway Ticket: The court rejected the argument that a used ticket isn’t a "valuable security," noting it could serve as proof for travel allowances or legal evidence.
- Conspiracy Allegations: Claims of collusion between the complainant and Advocate Saurabh Sharma were deemed evidentiary matters to be examined during trial.
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Key Legal Principles Reaffirmed
- Section 197 CrPC: Protects public servants but requires timely invocation.
- Charge Framing: Courts must assess broad probabilities without acting as a "post office" (Madhu Limaye vs. State of Maharashtra).
- Defence Evidence: Cannot be entertained at the charge-framing stage (State of Orissa vs. Debendra Nath Padhi).
Final Quote from the Judgment
"Without trial, the applicants cannot be discharged merely because evidence appears weak or allegations seem improbable."
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This ruling serves as a reminder of the balanced approach courts adopt in cases involving public servants, ensuring accountability while safeguarding against frivolous prosecutions.
Case Title: Rohit Chaturvedi & Another vs. The State of Madhya Pradesh & Another
Case No.: Criminal Revision No. 126 of 2025 (Neutral Citation: 2025:MPHC-JBP:36072)