Sodium Not An Explosive: Karnataka High Court Quashes FIR Against Content Creator Who Caused Explosion By Dropping Sodium Into Pond

The Court was hearing a petition under Section 482 CrPC, filed under Section 528 BNSS, seeking quashing of an FIR registered for offences under Section 3 of the Explosive Substances Act and Section 288 of the Bharatiya Nyaya Sanhita, 2023.

A Bench of Justice Suraj Govindaraj observed: “Sodium by itself is not an explosive substance, and in the present case, sodium was used in an experiment with water to establish the reaction that would be caused to demonstrate the reaction that would be caused between sodium and water. In fact, a write-up had also been provided which indicates the scientific formula in relation thereto as 2Na plus 2H2O gives rise to 2NaOH plus H2 plus heat energy; that is, sodium on reaction with water would form sodium hydroxide, hydrogen gas and heat energy in the form of an explosion. This is a general statement and/or information which is available in the textbook for the 10th Standard Science subject and it is this which was sought to be demonstrated by the petitioner who admittedly has created around 600 drones and is a content creator experimenting in science and these experiments are put up on the YouTube channel of the petitioner for the benefit of the students.”

The Court added: “As indicated supra, though this Court does not condone or commend the actions taken by the petitioner, the fact remains that it is not a malicious action but only an educative action on the part of the petitioner which would not require such an educator to go through the ignominy of a criminal investigation and or a criminal trial thereafter.”

Advocate Nazeefa M. Mulla and Sagar Salimath appeared for the petitioner, while High Court Government Pleader Rashmi Patel appeared for the State.

Background

The FIR arose from a police constable’s complaint alleging that the petitioner had dropped sodium into a pond at a private farm, causing an explosion that could have endangered people nearby.

The petitioner submitted that he was a science educator and online content creator who had conducted a controlled experiment to demonstrate the reaction between sodium and water for students studying the Class 10 NCERT syllabus.

According to the petitioner, an artificial pond measuring approximately 10 feet by 10 feet was created at his friend’s farm and filled with about 1,000 litres of water. Around 100 grams of sodium was then dropped into it, and the resulting video was uploaded to his YouTube channel.

The petitioner argued that the experiment was conducted away from residential and public areas, with the required precautions, and that neither Section 3 of the Explosive Substances Act nor Section 288 BNS was attracted.

The State submitted that the occurrence of an explosion was undisputed. It argued that the petitioner had knowingly combined sodium with water despite being aware that an explosion could result and that the investigation should therefore be permitted to continue.

Court’s Observations

Maliciousness Is An Ingredient Of Section 3

The Court examined Section 3(a) of the Explosive Substances Act, which applies where a person unlawfully and maliciously causes an explosion through an explosive substance of a nature likely to endanger life or cause serious injury to property.

The Court clarified that actual injury to a person or property was not necessary where the statutory ingredients were otherwise established.

The Court stated: “A perusal of Section 3 of the Act would indicate that any person who unlawfully and maliciously causes by any explosive substance an explosion of a nature likely to endanger life or to cause serious injury to property, shall, whether any injury to person or property has been actually caused or not, be punished with imprisonment for life or with rigorous imprisonment of either description, which shall not be less than 10 years and shall also be liable to fine.”

The Court noted that the case did not involve any “special category explosive substance” specified under Section 2(b), such as RDX, PETN, HMX or TNT. It therefore confined its consideration to Section 3(a) and the general definition of “explosive substance” under Section 2(a).

Sodium By Itself Was Not An Explosive Substance

The Court considered Section 2(a), under which an explosive substance includes material for making an explosive substance and any apparatus, machine, implement or material used or intended to cause or aid an explosion.

The Court explained: “An explosive substance shall be deemed to include any materials for making any explosive substance, also any apparatus, machine, implement or material used or intended to be used or adapted for causing or aiding in causing any explosion in or with any explosive substance. Also, any part of any such apparatus, machine or implement. A perusal of clause (a) of Section 2 of the Act would therefore indicate that the explosive substance should be materials for making any explosive substance, as well as any apparatus.”

Applying the provision, the Court held that sodium by itself was not an explosive substance. It noted that sodium had been combined with water to demonstrate a textbook chemical reaction producing sodium hydroxide, hydrogen gas and heat energy.

Experiment Was Educational, Not Malicious

The Court observed that the experiment had been conducted at the farm of the petitioner’s friend in a separately created pond. It further noted that the experiment had been recorded and voluntarily uploaded to the petitioner’s YouTube channel for students to view and understand.

The Court found that the petitioner had not attempted to conceal either the experiment or the resulting explosion. On the material contained in the complaint, it concluded that the maliciousness required by Section 3 could not be established.

The Court stated: “Though this Court does not endorse the manner in which the petitioner has conducted the experiment, considering that there is no maliciousness as required under Section 3 which could be established on the basis of the complaint which has been filed. The experiment has been conducted in the farm of the petitioner's friend, with a separate pond which had been built and which was recorded and uploaded on the YouTube channel, the petitioner had not sought to suppress the explosion or suppress the actions taken by the petitioner, but had voluntarily put up the same for the students to view and understand.”

The Court nevertheless made clear that it neither condoned nor commended the manner in which the petitioner conducted the experiment.

Conclusion

The Court allowed the criminal petition and quashed the FIR registered under Section 3 of the Explosive Substances Act, 1908, read with Section 288 BNS.

It cautioned that any further such action by the petitioner would be viewed strictly. The Court also granted him liberty to apply before the jurisdictional Magistrate for the return of material seized by the investigating officer.

Cause Title: Pratap N.M. v. State of Karnataka and Another (Neutral Citation: 2026:KHC:53677)

Appearances

Petitioner: Advocates Nazeefa M. Mulla and Sagar Salimath, for Advocate Shweta C. Hattarki

Respondents: High Court Government Pleader Rashmi Patel

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