The Madhya Pradesh High Court has declined to quash criminal proceedings against a man accused of circulating a WhatsApp message claiming that beef consumption was integral to being a “good Hindu” and that members of the Brahmin community frequently consumed beef.

The administrator of the WhatsApp group “B.P. Bauddh Patrakar News Group,” was booked after a complaint alleged that he had posted content claiming that consuming beef was essential for being a good Hindu, that Brahmins consumed bovine meat, and that cows and bulls were slaughtered in ancient rituals.

A bench of Justice Milind Ramesh Phadke held that the FIR, on its face, did disclose the ingredients of the invoked offences. It said, “The present matter involves allegations of publication or circulation of material capable of hurting religious sentiments or promoting disharmony. The allegations contained in the impugned FIR, when taken at their face value, disclose prima facie ingredients of the offences invoked.”

Advocate Aman Raghuwanshi appeared for the Petitioner and Advocate Padamshri Agarwal appeared for the State.

It further stated that questions such as whether the petitioner acted with malicious intent or in good faith, or whether the content was academic, could only be examined after evidence is collected during investigation. It added, “Whether the Petitioner acted with deliberate and malicious intention, whether the extract was quoted in good faith, and whether the content was merely academic or capable of disturbing public tranquillity and whether the Petitioner's post oversteps the permissible limits of free speech are the matters to be examined based on evidence collected during investigation. These are not issues that can be adjudicated at this preliminary stage.”

The Court added, “The plea of mala fides asserted by the Petitioner is also a question of fact, which would require evidence and cannot be conclusively determined in proceedings under Article 226 at the stage of investigation. The mere assertion that the FIR is a counterblast to earlier journalistic reports cannot, in itself, justify quashing of the FIR when the allegations otherwise disclose cognizable offences”

Concluding that no exceptional case was made out for exercising its extraordinary writ jurisdiction under Article 226, the Court dismissed the petition.

Cause Title: Buddha Prakash Bouddha v. The State Of Madhya Pradesh & Ors., [2025:MPHC-GWL:29778]

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Madhya Pradesh High CourtJustice Milind Ramesh Phadke

Suchita Shukla

Associate Editor

Suchita Shukla is an Associate Editor at Verdictum, with a strong foundation in legal research and writing, she brings over 4.5 years of experience to the table, having honed her skills in the dynamic field of law. She covers Supreme Court and High Courts. She completed her BA-LLB (Hons.) 5-year course with specialisation in Intellectual Property rights from Galgotias University. Since 2019, apart from having worked at a legal publishing house she has also ventured into legal journalism.