The Madhya Pradesh High Court, ruled that abducting a person from a public place, assaulting him, and coercing him to record a false self-incriminating video is a serious and heinous crime that affects society at large. The court observed that such acts cannot be dismissed lightly, even if there is a compromise between the parties involved.
The judgment was delivered by Justice Gurpal Singh Ahluwalia on April 4, 2025, in the case titled Sourav Gurjar And Others vs The State Of Madhya Pradesh And Others (M.Cr.C. No. 14536 of 2025).
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According to the FIR, the complainant, Paras Rathore, along with his father and friends, submitted a written complaint at the Bahodapur Police Station, District Gwalior. Paras, a resident of Jain Temple, Santar Morar, regularly visited his paternal aunt in Hatiyapaur. On March 11, 2025, while talking to his friends near the Shiv Temple, Sagartal, a white car without a number plate approached.
Inside the car were Lalit, Jashn Gill, Saurabh Gurjar, Deependra Kansana, and Vanshdeep. Jashn, who was familiar with Paras’s friend Raman, invited Paras into the car under the pretext of having a conversation with Lalit. Paras initially refused, stating he did not know Lalit. However, Deependra Kansana, who was driving, took Paras to a deserted area near Tighara Road.
There, the accused pointed a pistol at him and demanded ₹5,00,000. When Paras said he didn’t have the money, the accused threatened to shoot him. Out of fear, he mentioned having ₹16,000. He was then assaulted, and Jashn hit him with the butt of a pistol near his eye.
They forced him to transfer ₹16,000 through Google Pay and compelled him to hold the pistol while recording a video in which he was made to confess that he came to kill Deependra Kansana and that he had voluntarily given ₹16,000.
Later, the accused demanded another ₹4,84,000, threatening to release the video publicly and falsely implicate Paras if he told anyone about the incident. After being released, Paras returned home in a semi-conscious state due to the injury near his eye.
He informed his father and friends the next morning. Based on his complaint, a case was registered for offences under Sections 308(5), 127(2), 115(2), 296, and 3(5) of the Bharatiya Nyaya Sanhita (BNS), 2023.
Application for Quashing FIR
The accused later filed an application for quashing the FIR on the grounds of a mutual compromise between the parties involved. However, the court had to determine whether the nature of the allegations was minor or serious and harmful to society.
Court’s Observations
The court thoroughly examined the details of the FIR and emphasized the serious nature of the allegations:
"Abduction from a public place and then assaulting him by the butt of pistol and thereafter preparing a false video containing some self-incriminating admissions by complainant cannot be said to be an offence which is not heinous or not against the society."
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Justice Ahluwalia noted that the actions were not only criminal but posed a threat to public safety and societal values. The use of violence, coercion, and manipulation to produce a misleading video is far more than a private dispute — it is an act that undermines the justice system and instills fear in society.
Reference to Supreme Court Judgments
The court referred to two landmark Supreme Court decisions:
In Gian Singh vs State of Punjab (2012) and Narinder Singh & Others vs State of Punjab & Another (2014), the Supreme Court clearly held that heinous crimes that affect the fabric of society should not be quashed merely due to private settlements.
Considering the seriousness of the offence and its implications for society, the High Court dismissed the application to quash the FIR.
Case Title: Sourav Gurjar And Others Versus The State Of Madhya Pradesh And Others, Misc. Criminal Case No. 14536 Of 2025