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B.S. Solanki v. The State of Madhya Pradesh

Criminal Appeal · 2026 INSC 749Decided 24 Jul 2026
Crl.A. No.-003467-003467 - 2026 (@ Special Leave Petition (Crl.) No. 2668 of 2025)
Justice J.B. Pardiwala · Justice K. Vinod Chandran

Background

The appellant, an Assistant Registrar of Firms & Societies at Jabalpur, got caught up in a factional dispute within the Church of North India's Jabalpur Diocese and was named as a co-accused, along with the then Bishop, on allegations of forgery, cheating, and misappropriation under the IPC and the Prevention of Corruption Act. His sole alleged act was issuing a registration certificate reflecting a change of name for a diocesan educational trust/society, which carried an old registration date (1959) that the complainants claimed was a fabricated, forged date. The Madhya Pradesh High Court refused to quash the chargesheet against him.

Decision Breakdown

The Supreme Court examined the underlying registration documents and found the 1959 date was genuinely the original registration date of the society (later renamed), which continued to apply because of a statutory deeming provision carrying forward old registrations into the new 1973 Act. There was no forgery at all, only a straightforward name-change procedure the appellant had lawfully processed as Registrar. The Court also noted the alleged co-conspirator (the Bishop) was not even shown to be a member of the relevant governing councils at the time. Finding the appellant had no culpable role and that no civil dispute over the registration was even raised, the Court reversed the High Court, quashed the chargesheet against the appellant, and directed that the underlying criminal case not proceed against him.

Lesson Learnt

A public official performing a routine, legally correct administrative function (like registering a name change per an old registration date) should not be dragged into a criminal case arising from an unrelated factional dispute between other parties, and courts will quash such chargesheets where the record shows no genuine wrongdoing.

Official source (sci.gov.in)View Judgment (PDF)

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