MP High Court Refuses To Quash FIR In Disproportionate Assets Case

MP High Court Refuses To Quash FIR In Disproportionate Assets Case

The Indore Bench of the Madhya Pradesh High Court has refused to quash an FIR filed by the Lokayukta Special Police Establishment against Bhupendra Singh Bhati in a disproportionate assets case. The court held that investigation cannot be turned into a “mini-trial,” allowing the probe under the Prevention of Corruption Act to proceed.

Staff ReporterUpdated: Friday, February 20, 2026, 12:00 AM IST
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MP High Court Refuses To Quash FIR In Disproportionate Assets Case |

Indore (Madhya Pradesh): The Indore Bench of the Madhya Pradesh High Court has refused to quash an FIR registered in a disproportionate assets case registered by the Lokayukta Special Police Establishment Indore.

The High Court reportedly asserted that judicial proceedings cannot be used to conduct a "mini-trial" at the investigation stage. The division bench, comprising Justice Vijay Kumar Shukla and Justice Alok Awasthi, dismissed the petition filed by the accused Bhupendra Singh Bhati.

According to Lokayukta SP Rajesh Sahay, the case was registered under sections of the Prevention of Corruption Act, 1988 and the petitioner challenged the FIR on the grounds of alleged calculation errors. However, the court remained firm, stating that when prima facie evidence of an offence exists, the investigative process and subsequent prosecution must not be obstructed.

It is noteworthy that Lokayukta sleuths raided residential premises of chief account officer and general manager of Schedule Caste Financial Corporation (SCFC) Bhupendra Singh Bhati in 2012 and unearthed property worth Rs 2 crore , which is disproportionate to his known sources of income of Rs 45 lakh. 

During the proceedings, the officer-in-charge (OIC) informed the bench that fresh investigations confirmed the existence of assets significantly disproportionate to the accused's known income. Representing the Lokayukta, standing counsel Prasanna Prasad supported by SP Rajesh Sahay and investigating officer DSP Sunil Talan presented a compelling case against the dismissal.