Pradeep Kumar Jatav vs. The State Of Madhya Pradesh

Held

The Court held that the allegations against the applicant are serious. The prosecution case indicates that the applicant not only attempted to get his work done despite lacking proper documents but also tried to intimidate a public servant by maligning her dignity through social media posts. Upon perusal of the case diary, the Court found WhatsApp chats indicating threats and attempts at unlawful gain from the complainant. Considering the nature and gravity of the allegations, the manner of commission of the alleged offences, and the material available in the case diary, the Court was not inclined to exercise its discretionary relief under Section 482 of the BNSS in favour of the applicant. Therefore, the application for anticipatory bail was dismissed.

Facts

The petitioner, Pradeep Kumar Jatav, applied for GST registration, which was rejected on July 18, 2025, due to incomplete documentation. The complainant, Jaya Sharma, an Assistant Commissioner of GST, informed the petitioner of the deficiencies. The petitioner allegedly persisted in demanding registration, visited the complainant's office, claimed to be a journalist, and stated the rejection caused him a loss of approximately Rs. 20 lakhs. Subsequently, from December 2025 to March 2026, the petitioner allegedly posted defamatory and threatening content on Facebook and WhatsApp against the complainant and her family, demanding Rs. 1 crore. He also allegedly threatened to falsely implicate them in criminal cases. The FIR was lodged on May 21, 2026, for offences under Sections 308(2) and 308(6) of the BNS. The petitioner sought anticipatory bail, claiming innocence and false implication.

Key Issues

1. Whether the applicant is entitled to anticipatory bail under Section 482 of the BNSS, considering the serious nature of the allegations involving extortion, defamation, and intimidation of a public servant? Petitioner's arguments: The applicant is innocent and falsely implicated with an oblique motive. The allegations are based on seized electronic material, making custodial interrogation unnecessary. He claims to be a journalist who tried to expose unlawful acts, leading to his false implication. As a permanent resident, he poses no flight risk or risk of tampering with evidence. The trial will take a long time. Revenue/State's arguments: The State counsel vehemently opposed the bail application. The complainant's counsel also opposed, stating the applicant attempted to get illegal work done and maligned the complainant's dignity upon denial, thus not being entitled to bail.