The Supreme Court has set aside an interim order of the Allahabad High Court which had restrained the police from filing a chargesheet in a criminal case relating to alleged fraudulent sale of properties belonging to the Spiritual Regeneration Movement Foundation of India, a society established under the guidance of Maharishi Mahesh Yogi. 

The bench of Justice J.K. Maheshwari and Justice Atul S. Chandurkar observed that there was no justification for staying the filing of the police report under Section 193(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), particularly in a matter involving repeated allegations of forgery, cheating and illegal alienation of society land across several States. 

An appeal was filed by complainant Shrikant Ojha against the Allahabad High Court’s interim order passed in a writ petition seeking quashing of FIR No. 642 of 2025 registered at Police Station Noida Sector 39, Gautam Budh Nagar. The High Court had permitted investigation to continue but directed that the chargesheet should not be filed during pendency of the writ petition. 

The dispute concerns the Spiritual Regeneration Movement Foundation of India, a society registered under the Societies Registration Act, 1860, which owns substantial freehold immovable properties across different States. According to the case records, allegations have been made that unauthorized persons forged documents and illegally sold lands belonging to the society. Multiple civil suits and criminal proceedings have been initiated over the years in Uttar Pradesh, Chhattisgarh, Madhya Pradesh and Delhi concerning alleged fraudulent transfers of society property. 

The Supreme Court noted that several FIRs had already been registered against individuals allegedly involved in the transactions, including cases involving forged power of attorney documents and unauthorized sale of land. The present FIR alleged that certain persons, including directors of a private company, had purchased and further attempted to sell society land on the basis of forged documents despite earlier criminal cases already being pending. 

While examining the legality of the High Court’s interim protection, the Supreme Court referred extensively to its earlier decision in Neeharika Infrastructure (P) Ltd. v. State of Maharashtra and observed that blanket orders restraining coercive steps or interfering with investigation without proper reasons adversely affect the statutory powers of investigating agencies. The Court emphasized that the High Court was justified in granting limited protection against coercive action, but there was no basis for restraining the filing of the chargesheet. 

The Court also clarified the scope of its earlier judgment in Pradnya Pranjal Kulkarni v. State of Maharashtra, observing that the High Court had incorrectly relied upon that decision to stay filing of the police report. The Bench explained that the judgment merely clarified the distinction between exercise of writ jurisdiction under Article 226 and powers under Section 482 CrPC or Section 528 BNSS after cognizance is taken. According to the Court, the ruling did not authorize blanket directions preventing submission of chargesheets. 

Accordingly, the Supreme Court directed the Investigating Officer to complete investigation and file the report under Section 193(3) BNSS in connection with FIR No. 642 of 2025 registered under Sections 318(4), 336(3), 340(2) and 61(2) of the Bharatiya Nyaya Sanhita, 2023. 

Taking serious note of allegations that society lands were repeatedly being alienated without authorization, the Court further ordered constitution of a Special Investigation Team (SIT) under the supervision of the Chief Secretary of Uttar Pradesh. The Registrar of Societies has also been directed to be part of the SIT. The Bench directed the SIT to investigate how society properties were transferred to third parties without permission and to conduct a fact-finding inquiry into lands already sold. 

The Court observed that “land scams in India have been a persistent issue” and referred to its earlier ruling in Pratibha Manchanda v. State of Haryana dealing with organized land frauds and the role of land mafias. Stressing the need for an “unimpaired and unobstructed investigation,” the Bench stated that the SIT must act uninfluenced by any external force and ensure adherence to the rule of law. 

The Supreme Court directed that the SIT’s report be prepared within three months and furnished to the concerned police authorities and also be made available to the High Court in the pending proceedings. At the same time, the Court ordered that no coercive action should be taken against respondent No. 2 till the SIT submits its report and investigation is completed, subject to full cooperation with the investigation. 

The Court made strong observations regarding the internal disputes within the society and the continued sale of valuable properties despite ongoing civil and criminal litigation. 

The Bench remarked that the founder of the society could never have intended that internal friction among rival groups would result in alleged misuse and sale of society assets for personal gain.

Case Details

Case Title: Shrikant Ojha Versus State Of UP & Ors. 

Citation: JURISHOUR-1239-SC-2026

Case No.: Special Leave Petition (Crl.) No. 3123 of 2026

Date: 12/05/2026

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