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Shrikant Ojha v. State of UP & Ors.

Criminal Appeal · 2026 INSC 482Decided 12 May 2026
Crl.A. No.-002466-002466 - 2026 (arising out of SLP (Crl.) No. 3123 of 2026)
Justice J.K. Maheshwari · Justice Atul S. Chandurkar

Background

The appellant, a complainant connected to the Spiritual Regeneration Movement Foundation of India (a registered society founded under the guidance of Maharishi Mahesh Yogi that owned substantial immovable property), challenged an Allahabad High Court interim order which had allowed the police investigation to continue but barred the Investigating Officer from filing the police report while a writ petition filed by respondent No. 2 (one of the accused) remained pending. The background involved a long string of FIRs, spanning over a decade and multiple states, alleging that an unauthorized group had fraudulently sold and misappropriated the society's land using forged documents and fabricated office-bearer credentials.

Decision Breakdown

Without going into the merits of the underlying fraud allegations (since the appeal arose only from an interim order), the Supreme Court found the pattern of multiple FIRs and fraudulent land transfers warranted a coordinated, unimpeded investigation. Relying on its earlier decision in Pratibha Manchanda v. State of Haryana concerning organised land scams, the Court directed the constitution of a Special Investigation Team (SIT), to function under the supervision of the Chief Secretary of Uttar Pradesh and to include the Registrar of Societies as a member, to conduct a fact-finding inquiry into how the society's lands were alienated and to submit a report within three months. It directed that no coercive action be taken against respondent No. 2 until the SIT's investigation was complete, while requiring all accused persons to cooperate with the SIT.

Lesson Learnt

Where a property dispute is tangled up with parallel litigation and repeated allegations of fraud across multiple jurisdictions, the Supreme Court can step in to direct a coordinated, time-bound SIT investigation to cut through procedural gridlock, while still balancing this against protecting individuals from coercive action pending the outcome.

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

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