The Supreme Court of India has directed the constitution of a Special Investigation Team (SIT) to investigate the alleged fraudulent alienation of freehold lands belonging to the Spiritual Regeneration Movement Foundation of India, a society established by His Holiness Maharishi Mahesh Yogi. While hearing an appeal against an interim order of the Allahabad High Court, the Bench of Justice J.K. Maheshwari and Justice Atul S. Chandurkar set aside a direction that restrained the police from filing a charge-sheet, emphasizing that such “blanket orders” hinder statutory investigative powers.
The primary legal issue concerned the validity of an interim order passed by the High Court of Judicature at Allahabad, which stayed the submission of a police report (charge-sheet) under Section 193(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) while allowing the investigation to continue. The appellant, the complainant in the FIR, challenged this restraint.
The Supreme Court allowed the appeal, directing the Investigating Officer to complete the investigation and file the report. Furthermore, citing the gravity of organized land scams, the Court ordered the Chief Secretary of Uttar Pradesh to constitute an SIT, including the Registrar of Societies, to conduct a holistic fact-finding enquiry into the society’s land dealings across multiple jurisdictions.
Background of the Case
The Spiritual Regeneration Movement Foundation of India (“Society”), registered in 1963, holds extensive freehold properties across India. Following the death of its founder, Maharishi Mahesh Yogi, a management dispute emerged between two groups: one involving Sh. Ajay Prakash Srivastava and another including Sh. Chandra Mohan.
The Court noted a history of litigation, including:
- Civil Suits: Injunctions and declarations of unauthorized sale deeds in Takhtpur (Chhattisgarh) and Delhi (Saket Court).
- Multiple FIRs: Numerous FIRs registered in Chhattisgarh, Madhya Pradesh, and Uttar Pradesh (Noida) alleging fraud, forgery, and cheating (Sections 420, 467, 468, 471, and 120B of the IPC) related to the unauthorized sale of society land.
The present matter arose from FIR No. 642 of 2025 at PS Noida Sector 39, where it was alleged that G. Ram Chandramohan and others sold society land to M/s Singhvahini Infraprojects Private Limited using forged documents. Respondent No. 2, a director of the said company, sought quashing of this FIR before the High Court, which then stayed the filing of the charge-sheet.
Arguments of the Parties
The Appellant (Complainant) argued that unauthorized persons were repeatedly selling society land using forged documents despite existing court orders and multiple pending FIRs. They clarified that the lands were freehold and not leasehold, a fact not disputed by the State.
Respondent No. 2 (Director of the purchaser company) relied on precedents suggesting that civil disputes should not be criminalized. The High Court, in its interim order, had relied on Pradnya Pranjal Kulkarni v. State of Maharashtra (2025) to restrain the filing of the charge-sheet while the writ petition was pending.
Court’s Analysis
The Supreme Court scrutinized the High Court’s reliance on Pradnya Pranjal Kulkarni, stating it was “wholly unjust” as the facts were on a “completely different footing.” The Court clarified the distinction between invoking Article 226 of the Constitution (writ jurisdiction) and Section 528 of the BNSS (quashing power), noting that once a judicial order of cognizance intervenes, the nature of the challenge changes.
Referring to Neeharika Infrastructure (P) Ltd. v. State of Maharashtra (2021), the Court observed:
“29.1. That such a blanket interim order passed by the High Court affects the powers of the investigating agency to investigate into the cognizable offences, which otherwise is a statutory right/duty of the police…”
The Court expressed deep concern over the “land scams” and the “organised criminal networks” involved in exploiting such societies. Citing Pratibha Manchanda v. State of Haryana (2023), the Bench noted:
“29. Land scams in India have been a persistent issue… Scammers often create fake land titles, forge sale deeds, or manipulate land records to show false ownership… These land scams not only result in financial losses for individuals and investors but also disrupt development projects, erode public trust, and hinder socio-economic progress.”
The Decision
The Supreme Court issued the following directions:
- Charge-Sheet: The Investigating Officer is directed to complete the investigation and file the report under Section 193(3) of the BNSS in FIR No. 642 of 2025.
- Constitution of SIT: Under the supervision of the Chief Secretary of Uttar Pradesh, an SIT shall be formed. The Registrar of Societies will be a member to identify all lands belonging to the society and determine how they were alienated.
- Fact-Finding Report: The SIT must conduct a fact-finding enquiry and submit its report to the police within three months. If fraudulent acts with mens rea are found, the concerned police stations must take cognizance.
- Interim Protection: No coercive action shall be taken against Respondent No. 2 until the SIT submits its report and investigation is complete, provided the accused persons cooperate with the probe.
- Judicial Oversight: The SIT report must be made available to the High Court for its final decision in the pending writ petition.
The Court concluded by observing that it was never the founder’s intention that “friction within groups shall lead to fights” and the “valuable” property be sold for personal interest contrary to the society’s spiritual objects.
Case Details:
- Case Title: Shrikant Ojha v. State of UP & Ors.
- Case No.: Criminal Appeal No. ___ of 2026 (Arising out of SLP (Crl.) No. 3123 of 2026)
- Bench: Justice J.K. Maheshwari and Justice Atul S. Chandurkar
- Date: May 12, 2026
