IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR BEFORE HON'BLE SHRI JUSTICE SANJEEV SACHDEVA, CHIEF JUSTICE &

HON'BLE SHRI JUSTICE VINAY SARAF

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ON THE 27 OF FEBRUARY, 2026 WRIT PETITION No. 4830 of 2026 SHRI BHOLA PRASAD PATEL Versus THE STATE OF MADHYA PRADESH AND OTHERS Appearance:

Shri Jaideep Verma - Advocate for the petitioner.

Dr S.S. Chouhan - Government Advocate for respondent no.1/State Shri K.N.Fakhruddin - Advocate for respondent no.2.

ORDER Per: Hon'ble Shri Justice Vinay Saraf

1. The present petition is preferred by the petitioner challenging the legality and validity of the order dated 05.01.2026 passed by the Law and Legislative Affairs, Government of M.P., whereby the Notary licence issued in favour of the petitioner was revoked and the petitioner has been permanently debarred from practicing as a Notary.

2 . With the consent of parties heard Shri Jaideep Verma, learned counsel for petitioner and Dr.S.S.Chauhan - Government Advocate for the purpose of final disposal of the case.

3 . The petitioner is an enrolled advocate and by order dated

20.12.2000, the petitioner was appointed as Notary and permitted to carry out the practice of Notary at District Headquarter, Rewa for a period of 5 years, which was duly renewed for a further period of 5 years by the Law and Legislative Department, Government of M.P. vide order dated 22.05.2025 till 19.12.2030.

4. In Criminal Appeal No.6417/2024 (Archana Saket and others Vs.

State of M.P. and others) it was submitted before the Coordinate Bench that appellant Archana had performed a notarial marriage with co-accused Sandeep Saket and the copies of affidavits of marriage duly notarized by the petitioner were produced before the Court by the accused person therein and after examining the same, the Coordinate Bench by order dated 29.10.2025 issued direction to the Principal Secretary, Law and Legislative Department to take action against the petitioner i.e. Mr. B.P.Patel, Notary Rewa (M.P.) for performing notarial marriage on affidavit by holding that this kind of conduct on part of the concerned Notary needs thorough investigation that how Notaries (Public) are misusing their authority and executing documents as proof of marriage and it was further directed that the report be submitted within a period of 30 days.

5. In compliance of directions issued by the Coordinate Bench in Criminal Appeal No.6417/2024 on 29.10.2025, Third Civil Judge, Senior Division, Rewa (M.P.) was appointed as Inquiry Officer, who issued a notice to the petitioner on 06.12.2025 for production of the relevant documents on 08.12.2025. The statement of petitioner was recorded by the Inquiry Officer on 08.12.2025; wherein he admitted attestation of the marriage affidavits executed by Archana Saket and Sandeep Saket. After completing the inquiry, Inquiry Officer prepared an inquiry report on 8.12.2025 and forwarded the same to the Law and Legislative Department, State of M.P., Bhopal, wherein the Inquiry Officer had recorded a finding that the affidavits executed by Archana Saket dated 16.02.2022 and by Sandeep Saket dated 16.02.2022 were attested by the petitioner and the relevant entries in the notary register were available at Serial No.415 and 414 respectively. The Inquiry Officer has also recorded that before the Inquiry Officer, the petitioner admitted that he attested the affidavits of Archana Saket and Sandeep Saket evidencing their marriage.

6. After receipt of the inquiry report, a show cause notice was issued by the Law and Legislative Department to the petitioner on 11.12.2025 by forwarding the copy of inquiry report and granted him opportunity to submit his explanation. Further a detailed report was called from the Principal District Judge, Rewa by the Law and Legislative Department vide its Communication dated 12.12.2025 and the Principal District Judge issued a direction to the Inquiry Officer to submit a report in respect of the execution of other similar documents by the petitioner. The Inquiry officer