Chhattisgarh High Court Denies Quashing FIR Against Spiritual Practitioner Accused of Twenty Five Lakh Fraud

The High Court of Chhattisgarh at Bilaspur has dismissed a petition seeking the quashing of a First Information Report (FIR) filed against a man claiming to be a spiritual practitioner. The ruling, delivered by a Division Bench comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal, underscores the Court’s reluctance to interfere with ongoing criminal investigations involving disputed questions of fact.

A Faith-Based Dispute

The case stems from a complaint filed by a medical professional who alleged he was defrauded of approximately ₹25,10,000. According to the prosecution, the complainant, mourning the death of his younger brother, was introduced to the petitioner—Narendra Nayan Shashtri—in 2024. The complainant alleged that the petitioner claimed to possess divine powers capable of resolving familial hardships through specific religious rituals.

Over twenty-one months, the complainant purportedly attended over thirty ceremonies in locations spanning Raipur, Noida, and Indore, funding travel and ritual costs. When the promised results did not materialize and the petitioner allegedly began threatening the complainant’s family following requests for a refund, the complainant registered a criminal complaint under Section 318(4) of the Bharatiya Nyaya Sanhita, 2023.

Arguments from Both Sides

Counsel for the petitioner argued that the payments were entirely voluntary donations for spiritual guidance, describing the allegations as politically motivated and baseless. He further highlighted the twenty-one-month delay in filing the FIR, asserting that the proceedings were an abuse of the legal process.

Conversely, the State counsel maintained that the FIR disclosed a cognizable offence. The prosecution argued that the nature of the transactions, the intent behind the inducement, and the veracity of the petitioner’s claims were matters that could only be determined through a comprehensive investigation.

Judicial Analysis and Precedents

In its decision, the High Court emphasized the limitations of its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS). Referring to Supreme Court precedents such as Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra , the Bench reiterated that the Court cannot conduct a "mini-trial" or evaluate evidence at the investigation stage.

The Court noted that whether the payments were truly voluntary or obtained through deception are "disputed questions of fact" that require thorough factual adjudication.

Key Observations

The Court’s ruling offered significant insight into the threshold for quashing criminal proceedings:

  • "The jurisdiction to quash an FIR is extraordinary in nature and is required to be exercised sparingly, with great circumspection and only in exceptional cases."
  • "The inherent jurisdiction of this Court cannot be exercised to stifle a legitimate investigation merely because the accused disputes the allegations levelled against him."
  • "Whether the complainant was dishonestly induced to part with the amounts in question... are all disputed questions of fact which necessarily require a detailed investigation."

Final Ruling and Implications

The High Court ultimately refused to quash the FIR, ordering the investigative agency to proceed with the inquiry in accordance with the law, uninfluenced by any observations made during the petition. This judgment serves as a stern reminder that individuals seeking to bypass the investigation process must show that allegations are "patently absurd" or "inherently improbable," failing which, the legal process must be allowed to run its course.