Madhya Pradesh High Court Refuses To Quash Extortion FIR Against Journalist Shashikant Goyal

The Gwalior Bench of the Madhya Pradesh High Court has declined to quash an extortion FIR lodged against journalist Shashikant Jatav, alias Shashikant Goyal alias Shashi Kapoor, ruling that the allegations prima facie disclose a cognizable offence and that his defenses—retaliation claims and alleged police persecution—must be tested during trial.

When Journalism Meets an Extortion Allegation

The impugned FIR (No. 53/2025, P.S. Endori, District Bhind, June 1, 2025) followed a complaint by Kaptan Singh Kushwaha, Sarpanch of Sherpur Gram Panchayat. Kushwaha alleged that the petitioner and another journalist, Pritam Singh, had approached him 8–9 months earlier and threatened to file complaints and publish false news against him unless he paid ₹50,000. The FIR invoked Sections 308(2), 308(4), 308(6), 308(7), 296 and 351(2) along with Section 3(5) of the Bharatiya Nyaya Sanhita (BNS).

The petitioner, however, painted an entirely different picture. He had authored investigative reports in the Bejod Ratna newspaper in May and June 2024, exposing an alleged ₹25-lakh corruption scam in the Sherpur Gram Panchayat—reports that triggered official suspensions and attachment of panchayat property. He argued the complaint was a "blow-back" filed with an unexplained 8–9 month delay, just one day after the Supreme Court had granted him a protection order.

A Tale of Police Coercion and a Coerced Video

The petitioner's case carried extraordinary allegations against the district's top police officer. He claimed that after publishing reports on the Chambal sand mafia and alleged police excesses, he and fellow journalists were "invited" to the office of SP Dr. Asit Yadav under the pretext of tea, only to be allegedly assaulted and intimidated. He further alleged that on the night of May 4–5, 2025, he and journalist Amarkant Singh Chouhan were intercepted, taken to the SP's bungalow at 3 AM, threatened with false prosecutions, and forced to record a coerced video statement claiming the matter was "resolved." Subsequent events—a press conference in Bhopal, a CM Helpline complaint, and a medical examination confirming "trauma and abrasions"—were pressed into service to bolster the claim of systematic persecution.

The State's Counter: An 'Organized Gang' of Extorting Media

Respondents rejected this narrative, branding the petitioner an "opportunist" who misused his journalistic position for extortion and blackmail. They drew the Court's attention to a 'Special Information' notice issued by the Inspector General of Police, Chambal Zone—an official warning flagging an "organized gang of YouTubers/WhatsApp news" demanding money from sarpanchs, teachers, mining officials and others, describing such conduct as extortion punishable with life imprisonment. This material, the respondents argued, demonstrated that the complaints were not born of revenge or personal grudges.

Why the Court Declined to Interfere

Justice Rajesh Kumar Gupta applied the settled benchmark from State of Haryana & Ors. v. Bhajan Lal & Ors. (1992 Supp (1) SCC 335) and found that while the petitioner claimed retaliation and mala fides , the respondents had placed on record material pointing to a "broader pattern of alleged systematic extortion by certain local media elements" in the district. Such contentions, the Court held, are "matters of evidentiary value that require proper testing during trial" and cannot justify summary termination of criminal proceedings.

Key Observations

  • "This Court is of the considered opinion that no case for interference or quashing of the impugned FIR at this nascent stage is made out under Article 226 of the Constitution of India ."
  • "The extraordinary powers under Article 226 or Section 482 of the CrPC / Section 528 of the BNSS ought not to be exercised to stifle a legitimate prosecution where the allegations, prima facie , disclose the commission of a cognizable offence ."
  • "The defense of mala fides , institutional friction, or prior journalistic exposés are matters of evidentiary value that require proper testing during trial and cannot serve as grounds for a summary termination of criminal proceedings."

Decision and Takeaway

The writ petition was dismissed, with interim orders vacated. The Court clarified that its observations are confined to the disposal of the petition and will not prejudice either party at trial. The judgment reinforces a key legal principle: investigative journalism, however valuable, does not insulate a journalist from trial where an FIR prima facie discloses extortion—and claims of police persecution must yield to evidentiary scrutiny before a trial court.