In a significant ruling on January 22, 2025, the Supreme Court of India, led by Justice Sanjay Karol and Justice Manmohan, clarified the legal requirements for invoking Section 295A of the Indian Penal Code (IPC). The judgment, delivered in Manish Kumar Singh & Anr. v. State of Chhattisgarh (Criminal Appeal No. 401 of 2025), quashed an FIR against two employees of South Eastern Coalfields Limited. The Court emphasized that the essential ingredient of mens rea—a deliberate and malicious intention to insult religion—is critical to prosecuting offenses under Section 295A IPC.
Case Background
The case revolved around an FIR filed under Section 295A IPC at Police Station Chirmiri, District Manendragarh-Chirmiri-Bharatpur, Chhattisgarh. The appellants, employees of South Eastern Coalfields Limited, were accused of hurting religious sentiments during the relocation of remnants of the Sati Mandir.
The relocation was carried out to address a fire in underground coal mines near the temple. The fire posed a significant threat to the structure and public safety. Following the directions of the High Court of Chhattisgarh in WP PIL No. 150 of 2022, the appellants, under the supervision of the local Sub-Divisional Magistrate (SDM), facilitated the shifting of the temple artifacts and remnants to a temporary museum. Despite the compliance with judicial orders, an FIR was registered, alleging that the relocation outraged religious sentiments. The appellants sought relief from the Supreme Court, challenging the legality of the FIR.
Important Legal Issues
The Court considered the following legal questions:
1. What constitutes an offense under Section 295A IPC?
2. Does compliance with judicial and administrative directions preclude the existence of malicious intent under Section 295A IPC?
3. When can an FIR be quashed under the Court’s extraordinary powers?
Important Observations of the Court
The Supreme Court extensively analyzed Section 295A IPC, which penalizes deliberate and malicious acts intended to insult religious beliefs. The Court identified three essential ingredients for invoking Section 295A:
1. Intent to Outrage Religious Feelings: The act must involve an insult or attempt to insult religion or religious beliefs.
2. Mode of the Act: The insult must occur through words, signs, visible representations, or other means.
3. Mens Rea (Malicious Intent): The act must be carried out with deliberate and malicious intent to provoke religious outrage.
Justice Manmohan remarked, “The opening words ‘with deliberate and malicious intention’ in Section 295A postulate the necessity of mens rea. Without such intent, the invocation of this section is unsustainable.”
The Court found that the appellants’ actions were in strict compliance with the High Court’s directions and aimed at addressing a serious environmental and public safety threat posed by the mine fire. The Court observed, “None of the acts of the appellants can be said to be consciously designed to provoke or insult religious beliefs.”
The bench also highlighted that the allegations in the FIR were inherently improbable and absurd, as the appellants acted under the supervision of local authorities.
Decision of the Court
The Supreme Court quashed the FIR against the appellants, underscoring the absence of malicious intent. The judgment clarified that mere procedural compliance, undertaken in good faith, cannot be construed as an insult to religious beliefs. Justice Manmohan observed, “If the SDM believed the High Court’s orders were disobeyed, the proper recourse was to approach the Court, not file an FIR.”
By quashing the FIR, the Court reinforced the principle that Section 295A IPC must be interpreted strictly to prevent misuse. The judgment safeguards individuals acting under lawful authority from frivolous prosecutions, while balancing the protection of religious sentiments and the right to perform administrative and judicially mandated duties.
