The Madhya Pradesh High Court has quashed criminal proceedings against former cabinet minister Bansh Mani Verma, ruling that the allegations of abusive remarks made during a political protest did not constitute offences under Sections 294 and 504 of the Indian Penal Code (IPC).
The Court observed that criticism or harsh language used in a political context cannot automatically be treated as criminal obscenity or intentional provocation unless the legal ingredients of those offences are clearly established.
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Background of the Case
The case arose from an incident on 23 July 2021, when members of the Indian National Congress organized a protest rally in Waidhan, Singrauli district, against rising inflation.
According to the prosecution, during the protest near the Collectorate while submitting a memorandum to district authorities, Bansh Mani Verma allegedly used objectionable language against the Collector and the district administration.
Following directions from the Sub-Divisional Magistrate, an FIR was registered on 25 July 2021 at Police Station Waidhan under Section 294 IPC (obscene acts or words in public). After investigation, police also added Section 504 IPC, which relates to intentional insult intended to provoke breach of peace. A chargesheet was later filed and the case was pending before the Chief Judicial Magistrate, Singrauli.
Verma then approached the High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking quashing of the chargesheet and the criminal proceedings.
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Arguments by the Petitioner
Counsel for the petitioner argued that the entire prosecution was based on vague allegations.
It was submitted that the FIR did not mention the exact abusive words allegedly used by Verma, nor did it show that any obscene act or utterance caused annoyance to the public, which is required to establish an offence under Section 294 IPC.
The petitioner further argued that the alleged remarks were part of political criticism of the administration during a protest. At best, such statements could amount to criticism of governance but not criminal obscenity or intentional insult.
Another point raised was that the complainant was a Patwari who lodged the FIR on instructions from the Sub-Divisional Officer, even though the alleged remarks were said to be directed at the Collector. The petitioner also highlighted that despite the protest being a public event, no independent public witnesses were cited in the case.
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State’s Stand
The State opposed the petition, arguing that the language used by the petitioner during the protest was inappropriate and capable of disturbing public order.
Government counsel submitted that the incident took place in a public gathering and the remarks were insulting toward public authorities, which could amount to offences under Sections 294 and 504 IPC.
The State further contended that the FIR and chargesheet disclosed cognizable offences and therefore the High Court should not interfere at the initial stage of prosecution.
Court’s Observations
Justice Himanshu Joshi examined the legal requirements of Sections 294 and 504 IPC and the material placed on record.
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The Court noted that for an offence under Section 294 IPC, the prosecution must clearly establish that obscene words were used in a public place and that they caused annoyance to the public.
The judge observed that the words allegedly used by the petitioner, including expressions like “nalayak,” may be considered derogatory in some contexts but cannot automatically be classified as obscene language.
“The material placed on record does not disclose that any obscene act was committed or that the alleged utterances caused annoyance to the public,” the Court noted.
On the charge under Section 504 IPC, the Court said the offence requires intentional insult with the knowledge that such provocation could lead someone to breach public peace.
The Court found that the alleged remarks were made during a political protest about public issues and were directed at the functioning of the administration. It also noted that the Collector, against whom the remarks were allegedly made, was not present at the location.
“Mere criticism or use of harsh words against an administrative authority during a political protest… would not constitute the offence under Section 504 IPC,” the Court observed.
The Court also highlighted that no independent witnesses from the public were cited, even though the protest took place in a public setting.
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Court’s Decision
After examining the FIR and the investigation record, the High Court concluded that the allegations, even if accepted at face value, did not satisfy the ingredients of offences under Sections 294 or 504 IPC.
The Court held that continuing the prosecution in such circumstances would amount to abuse of the legal process.
Accordingly, the High Court allowed the petition and quashed the FIR, the chargesheet, and the criminal proceedings pending before the Chief Judicial Magistrate, Singrauli.
Case Title: Bansh Mani Verma vs State of Madhya Pradesh & Others
Case No.: MCRC No. 55648 of 2024
Decision Date: 5 March 2026
