Journalism, Extortion Allegations, and Limits of Writ Jurisdiction: MP High Court Refuses to Quash FIR Against Journalist

The Madhya Pradesh High Court has refused to quash an FIR registered against journalist Shashikant Jatav alias Shashikant Goyal alias Shashi Kapoor, who was accused of extortion by a doctor in Bhind district. Delivering the ruling in Shashikant Jatav @ Shashikant Goyal @ Shashi Kapoor v. State of Madhya Pradesh and Others, Justice Rajesh Kumar Gupta observed that allegations of mala fide intent or political vendetta cannot, by themselves, justify interference when the complaint prima facie discloses a cognizable offence.

The FIR was lodged after Dr. Harmendra Singh Kushwaha alleged that the petitioner and another journalist visited his clinic and demanded ₹5,000 per month, threatening to publish repeated reports against him for allegedly practising allopathy without proper authorization. The prosecution further relied upon WhatsApp communications and a news report published in the Bejod Ratna newspaper.

The petitioner argued that the FIR was retaliatory and intended to silence his reporting on illegal sand mining and alleged police misconduct in the Chambal region. He also referred to complaints filed before the Press Council of India and the National Human Rights Commission regarding alleged custodial violence by police officials.

However, the Court held that disputed questions regarding whether the acts constituted legitimate journalism or extortion could only be examined during investigation and trial. Relying on the principles laid down in State of Haryana v. Bhajan Lal, the Bench observed that the case did not fall within the exceptional categories warranting quashing of criminal proceedings at the threshold.

The judgment reinforces a significant legal principle: courts exercising writ jurisdiction under Article 226 ordinarily will not interfere with criminal investigations when the FIR discloses prima facie commission of cognizable offences, even where allegations of political targeting or personal vendetta are raised.