Supreme Court Directs SIT Probe Into Alleged Fraudulent Sale Of Spiritual Regeneration Movement Foundation Of India Lands
The Court also held that the Allahabad High Court was not justified in restraining the filing of the police report under Section 193(3) BNSS while permitting the investigation to continue.
The Supreme Court has directed the constitution of a Special Investigation Team under the supervision of the Chief Secretary of Uttar Pradesh to conduct a fact-finding enquiry into alleged unauthorised sale and transfer of lands belonging to the Spiritual Regeneration Movement Foundation of India.
The Court directed that the Registrar of Societies shall be made a member of the SIT and that the enquiry shall ascertain how lands belonging to the society were alienated or transferred to third parties without permission of the society.
The Court was hearing an appeal challenging an interim order passed by the Allahabad High Court in proceedings arising out of an FIR alleging the sale of society lands on the basis of forged documents. While permitting investigation to continue, the High Court had directed that the police report under Section 193(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023, shall not be submitted during the pendency of the writ petition.
A Bench of Justice J.K. Maheshwari and Justice Atul S. Chandurkar observed: “... we deem it appropriate to direct under the supervision of Chief Secretary of the Uttar Pradesh an SIT to be constituted wherein the Registrar of Societies shall be made one of its members who can disclose the lands belonging to the society concerned and thereafter it should be found out that how the lands belonging to the society have been alienated or transferred to any third party without the permission of the society".
Background
The dispute concerned the Spiritual Regeneration Movement Foundation of India, a society registered under the Societies Registration Act, 1860. The judgment records that the society was established under the guidance of Maharishi Mahesh Yogi, “for the dissemination of spiritual upliftment and benefit of the society at large,” and owned freehold immovable properties.
According to the appellant, several criminal cases and civil proceedings had been initiated in different States alleging illegal sale of society lands by unauthorised persons through forged documents. The judgment records the pendency of multiple FIRs and litigations concerning the alleged sale of society properties in Chhattisgarh, Uttar Pradesh and Madhya Pradesh.
The Court also noted that although it had initially proceeded on the assumption that the lands were government leasehold properties, it was later informed during the hearing that the lands were freehold properties, a position that was not disputed by the State.
In the present matter, an FIR had been registered alleging that society land had been sold to a private company based on forged documents. Respondent no.2, one of the directors of the purchasing company, approached the Allahabad High Court seeking the quashing of the FIR.
Aggrieved by the High Court’s interim direction restraining the filing of the police report under Section 193(3) BNSS, the complainant approached the Supreme Court.
Court’s Observation
The Supreme Court noted that the material placed before it disclosed a dispute between rival groups claiming management and control over the society. Referring to the report submitted by the Registrar of Societies, the Court recorded that two different groups were claiming to be office bearers of the society.
The Court further observed that multiple criminal proceedings concerning the sale of society lands had been registered across different States and expressed concern that, despite the pendency of civil and criminal proceedings, society properties continued to be sold. The Bench observed: “It is a matter of concern to this Court in particular when a number of criminal cases on account of selling of the property of the society have been registered at various jurisdictions in different States.”
While examining the legality of the High Court’s interim order, the Supreme Court referred to Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra (2021) and reiterated that blanket interim orders restraining investigation or coercive steps adversely affect the statutory powers of the investigating agency.
The Court then examined the High Court’s reliance on Pradnya Pranjal Kulkarni v. State of Maharashtra (2025). The Bench observed that the said judgment explained the distinction between the High Court’s jurisdiction under Article 226 of the Constitution and the remedies available under Section 528 BNSS after cognisance is taken. The Court held that the said decision had been incorrectly relied upon by the High Court while restraining the filing of the police report.
Holding that the interim direction could not be sustained, the Court observed: “However, from the reading of the judgment of Pradnya Pranjal Kulkarni (supra), we do not find any reason to direct stay on filing of the chargesheet under Section 193(3) of the BNSS.”
The Court accordingly directed the Investigating Officer to complete the investigation and submit the report under Section 193(3) BNSS.
Considering the allegations regarding repeated sale of society lands, the Court referred to Pratibha Manchanda v. State of Haryana (2023), wherein the Supreme Court had directed the constitution of an SIT for “unimpaired and unobstructed investigation” in matters involving alleged land scams.
The Bench thereafter directed the constitution of an SIT under the supervision of the Chief Secretary of Uttar Pradesh and ordered that a fact-finding enquiry be conducted regarding lands allegedly sold without authority. The Court further directed that the report shall be handed over to the concerned police authorities within three months and, if fraudulent acts involving mens rea are disclosed, cognisance be taken in accordance with law.
The Court also directed that no coercive action shall be taken against respondent no.2 till submission of the SIT report and completion of the investigation, while directing all accused persons to cooperate with the SIT and investigation.
Expressing concern over the continued sale of society properties despite pendency of litigation, the Court observed that after the death of Maharishi Mahesh Yogi, “it was also not intended by him that despite pendency of litigation on the civil and criminal side, the office bearers of the society shall not have any fear and will continuously involve in selling the property.”
The Court clarified that it was not expressing any opinion on the merits of the allegations since the appeal arose from an interim order.
Conclusion
The Supreme Court set aside the Allahabad High Court’s direction restraining the filing of the police report under Section 193(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023 and directed the Investigating Officer to complete the investigation and file the report in accordance with the law.
The Court further directed the constitution of a Special Investigation Team under the supervision of the Chief Secretary of Uttar Pradesh to conduct a fact-finding enquiry into the alleged unauthorised transfer and sale of lands belonging to the Spiritual Regeneration Movement Foundation of India. The SIT was directed to submit its report within three months.
Cause Title: Shrikant Ojha v. State of Uttar Pradesh & Ors. (Neutral Citation: 2026 INSC 482)
