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2026 Supreme(Online)(MP) 36755

IN THE HIGH COURT OF MADHYA PRADESH AT GWALIOR
Rajesh Kumar Gupta, J
Pradeep Kumar Jatav – Appellant
Versus
State of Madhya Pradesh – Respondent
MISC. CRIMINAL CASE No. 28051 of 2026



Advocates:
For the Appellants/Petitioners: Abhishek Jat
For the Respondents: Dinesh Savita, Pramod Kumar Pachori

Anticipatory bail may be denied when the gravity of allegations involves the intimidation of a public servant, extortion, and the use of social media to defame and blackmail, especially when supported by electronic evidence like WhatsApp chats.

Headnote:The applicant sought anticipatory bail under Section 482 of the BNSS in relation to Crime No. 394/2026 registered for offences punishable under Sections 308(2) and 308(6) of the BNS. The facts involve allegations that after the rejection of a GST registration application due to non-compliance with statutory rules, the applicant harassed the complainant, a public servant, by publishing defamatory material on social media and demanding an illegal payment of Rs. 1 crore. The court found that the applicant allegedly threatened to falsely implicate the complainant's family in serious criminal cases if the money was not paid. The primary issue was whether the applicant was entitled to discretionary relief of anticipatory bail given the nature of the allegations. The court reasoned that the allegations are serious in nature, involving the intimidation of a public servant and attempts to malign her dignity. The court noted that the case diary contained WhatsApp chats indicating threats and motives for unlawful gain, which outweighed the applicant's contention of being a journalist uncovering unlawful acts. Accordingly, the application fails and is hereby dismissed.

Table of Content
1. allegations of extortion and defamation against a public servant using social media. (Para 1 , 2 , 3)
2. applicant's claim of journalistic activity versus prosecution's claim of blackmail. (Para 4 , 5 , 6)
3. denial of bail due to gravity of offence and evidence of threats. (Para 7 , 8 , 9 , 10)

ORDER

1. This is first application filed under Section 482 of BNSS for grant of anticipatory bail.

2. The applicant apprehends his arrest in connected with Crime No.394/2026 registered at Police Station Kotwali, District Shivpuri (M.P.) for offence punishable under Sections 308(2), 308 (6) of BNS.

3. As per the prosecution case, the complainant, Jaya Sharma, is posted as Assistant Commissioner, GST, Shivpuri. It is alleged that Pradeep Kumar Jatav, a resident of Badarwas, had submitted an application for GST registration through his acquaintance, Gaurav Bhargava, before the office of the complainant. However, the application was not accompanied by a valid identity proof and other requisite documents. Since the application did not comply with the prescribed requirements and statutory rules, it was rejected on 18.07.2025. According to the prosecution, despite being informed about the deficiencies in the application and being advised to complete the requisite formalities for obtaining registration, the applicant persistently insisted that the GST registration be granted in violation of the prescribed procedure. It is alleged that he repeatedly visited the complainant's office, introducing himself as a journalist, and demanded that his application be approved. As the registration was not granted, the applicant allegedly developed a grudge against the complainant. It is further alleged that after the rejection of the application, the applicant visited the complainant's office and stated that the rejection of his GST registration had caused him a loss of approximately Rs. 20 lakhs and that she would have to compensate him for the same. Thereafter, on 07.12.2025, the applicant allegedly sent several WhatsApp messages to the complainant containing false, defamatory and derogatory material against her and threatened that such news would be published. It is further alleged that on 08.12.2025, he again sent threatening messages to the complainant through WhatsApp. The prosecution further alleges that on 11.12.2025, a news item was uploaded from a Facebook account in the name of Pradeep Kumar Jatav containing allegations against the complainant. Thereafter, on 13.12.2025, another post was uploaded on Facebook containing a photograph of the complainant's residence along with the name of her brother's academy. Again, on 16.12.2025, another Facebook post was made displaying a photograph of her residence with allegations that the arrival of the Economic Offences Wing (EOW) had caused commotion and that transactions involving property worth crores situated on Collector Kothi Road were under discussion. It is further alleged that on 22.12.2025, another Facebook post was published using the complainant's name and photograph without her consent, making allegations of corruption against her. Thereafter, on 27.12.2025, another post was uploaded displaying a photograph of her residence with allegations that her brother had constructed a luxurious house worth crores from the complainant's alleged black money. On 29.12.2025, another Facebook post was published containing the photograph of her brother, Alok Sharma. Subsequently, on 12.01.2026, a Facebook post was uploaded containing the photograph of her sister-in-law, Pooja Sharma. Thereafter, on 28.01.2026 and again on 18.03.2026, further posts relating to the complainant's office were allegedly published on Facebook. According to the prosecution, when the complainant confronted the applicant regarding the continuous publication of false and misleading news against her, he allegedly demanded an illegal payment of Rs. 1 crore from her and threatened that if the amount was not paid

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