News Citation : 2026 LN (HC) 228
April 1, 2026 : In a significant ruling protecting public servants from harassment, the Madhya Pradesh High Court at Jabalpur has quashed criminal proceedings against several Railway Vigilance officers, citing a lack of jurisdiction and a clear abuse of the legal process. Justice B. P. Sharma ruled that the prosecution of these officers, who were performing their official duties during a train inspection, could not proceed without mandatory government sanction.
The case originated from a 2011 incident where a team of Vigilance Inspectors from the West Central Railway conducted an inspection of a Ticket Examiner, Pyar Singh Meena, aboard the Rewa-Jabalpur Intercity. Following the inspection, Meena alleged he was subjected to caste-based slurs, physical harassment, and mental torture. While an initial investigation by the Government Railway Police (GRP) in Jabalpur found no evidence of a crime, a second case was later registered at GRP Katni.
The petitioners—Sunil Kumar Shrivastava, Hemant Rakesh, and Neeraj Kukreja—argued that the case was a retaliatory move influenced by high-ranking officials sharing the complainant’s caste. They pointed out that an inquiry conducted by the Superintendent of Police (Rail) under previous High Court directions had already exonerated them, finding only one other officer potentially liable.
Justice Sharma highlighted several “unusual” aspects of the case, specifically noting that the complaint was entertained by the Inspector General of Police in Rewa, an official who lacked territorial jurisdiction over the incident. The Court described this as a “clear departure from settled jurisdictional discipline” and suggested the process was influenced by “extraneous considerations” and social proximity between the complainant and the then-IG.
Central to the judgment was the application of Section 197 of the CrPC, which protects public servants from prosecution for acts committed in the discharge of official duty. The Court emphasized that even if an officer acts in excess of their authority, they are protected if there is a “reasonable nexus” to their official work. In this instance, the alleged altercation happened strictly within the context of a professional vigilance check.
The High Court concluded that the proceedings were “wholly unjustified” and “mala fide,” initiated with the intent to humiliate the officers. By quashing the 2015 summons and the underlying FIR at GRP Katni, the Court reaffirmed that legal protections for public servants are not mere formalities but essential safeguards against the abuse of power.
Case Reference : WP-4640-2015 (Sunil Kumar Shrivastava), WP-4639-2015 (Hemant Rakesh), and WP-4642-2015 (Neeraj Kukreja) vs. The State of Madhya Pradesh and Others
