IN THE HIGH COURT OF MADHYA PRADESH AT INDORE BEFORE HON'BLE SHRI JUSTICE VIJAY KUMAR SHUKLA &

HON'BLE SHRI JUSTICE ALOK AWASTHI

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ON THE 17 OF FEBRUARY, 2026 MISC. CRIMINAL CASE No. 39596 of 2025 BHUPENDRA SINGH BHATI Versus SPECIAL POLICE ESTABLISHMENT Appearance:

Shri Rajendra Kumar Mishra with Shri Yashpal Singh Sisodiya -

Advocate for the applicant.

Shri Prasanna Prasad - Advocate for the respondent.

ORDER Per: Justice Vijay Kumar Shukla This petition under Section 528 of BNSS, 2023 has been preferred for quashment of criminal proceedings registered at Crime No.211/2012, by Special Police Establishment Lokayukt, Indore, District Indore against the applicant for the offences punishable under Sections 13(1)(e) and 13(2) of the Prevention of Corruption Act, 1988.

2. Facts of the case are that the applicant was working as Chief Executive Officer under the Madhya Pradesh Anusuchit Jati Vitt Vikas Nigam. He was posted at Bhopal in 2012, when search was conducted by the respondent at the house of applicant on 14.10.2012. The respondent registered an offence bearing no.211/2012, under Sections 13(1)(e) and

13(2) of the Prevention of Corruption Act, 1988. The respondent seized various documen