Land, Fraud, and the Law: How the Supreme Court Stepped In to Protect Maharishi Mahesh Yogi’s Legacy
Introduction: A Society Founded on Spiritual Purpose, Caught in Legal Turmoil
The Spiritual Regeneration Movement Foundation of India (SRMFI) was established under the divine guidance of His Holiness Maharishi Mahesh Yogi — the renowned transcendental meditation teacher who influenced generations worldwide — with the singular mission of spiritual upliftment and the broader benefit of society. Registered under the Societies Registration Act, 1860, bearing registration No. S-2366 of 1963, the SRMFI holds freehold immovable properties across multiple states in India.
But in recent years, this institution of spiritual purpose has been engulfed in a bitter dispute over the unauthorized disposal of its vast landholdings. Multiple criminal cases, civil suits, and competing factions claiming management rights have turned what should have been a legacy of peace into a battlefield of litigation. On May 12, 2026, the Supreme Court of India finally intervened decisively — ordering the constitution of an SIT and setting aside a controversial High Court order that had effectively shielded accused persons from a chargesheet.
Background: Who Is Selling the Society’s Lands?
A MANAGEMENT IN DISPUTE
At the heart of this case is a fractured management structure. According to a report filed by the Office of the Registrar of Society, submitted before the Supreme Court, the SRMFI is locked in an internal battle between two rival groups — one led by Sh. Ajay Prakash Srivastava, and the other by Sh. G. Ram Chandramohan. Both groups claim to represent legitimate office bearers of the society.
“As per the records available in the file, there seems to be a dispute among two groups of the management of the society… the society has two different lists of office bearers.”
—OFFICE OF THE REGISTRAR OF SOCIETIES, AS QUOTED IN THE SUPREME COURT’S JUDGEMENT
This management vacuum, the Court noted, was being exploited. The unauthorized group, allegedly led by G. Ram Chandramohan, reportedly sold the society’s lands across several states — including Chhattisgarh, Uttar Pradesh, and Madhya Pradesh — using forged documents and power of attorneys.
A CASCADE OF FIRS ACROSS INDIA
The fraudulent transactions triggered a wave of First Information Reports registered across multiple states and jurisdictions. The timeline of these FIRs reveals the sheer scale of the alleged wrongdoing:
2011 – FIR No. 328/2011 registered at PS Takhatpur, Bilaspur, Chhattisgarh — against G. Ram Chandramohan for alleged sale of society’s land in villages Devri and Khamaria, Bilaspur.
2014 – FIR No. 486/2014 registered at PS City Kotwali, Baloda Bazar, Bhatapara — additional criminal complaint against the unauthorized group.
2023 – FIR No. 294/2023 registered at PS Noida Sector 39 — for alleged fraudulent disposition of society’s property to third parties.
JAN 2024 – FIR No. 20/2024 at PS Bargi, Jabalpur — against G. Ram Chandramohan and Awadesh Pandey for forged power of attorney. Quashing petition dismissed by MP High Court.
2024 – FIR No. 68/2024 at PS Shajapur — concerning alleged fraudulent sale of 199 bigha 8 biswa of land.
DEC 2025 – FIR No. 642/2025 at PS Noida Sector 39 — the trigger for the present Supreme Court case. Alleged sale of society’s land to M/s Singhvahini Infraprojects Pvt. Ltd. on the basis of forged documents.
Despite ongoing FIRs, civil injunctions, and even a 2020 civil court ruling holding that certain sale deeds were not binding on the society, the alleged unauthorized disposals continued. The Supreme Court pointedly noted that those selling the society’s properties appeared to have no fear of the law, proceeding with transactions even while litigation was actively pending.
The Allahabad High Court Order: What Went Wrong?
Respondent No. 2 — Raghvendra Pratap Singh, a director of M/s Singhvahini Infraprojects Private Limited — filed a writ petition before the Allahabad High Court seeking to quash FIR No. 642 of 2025. While hearing the petition, the High Court passed an interim order dated February 6, 2026, staying the arrest of the accused and — crucially — directing that the police report (chargesheet) under Section 193(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) shall not be submitted to court for the duration of the writ petition’s pendency.
The High Court grounded its reasoning in two sets of precedents: Mohd. Ibrahim v. State of Bihar (2009) and Jit Vinayak Arolkar v. State of Goa (2025), arguing that where a civil dispute underlies an FIR, criminality may not be sustainable. It further relied on the Supreme Court’s own judgment in Pradnya Pranjal Kulkarni v. State of Maharashtra to justify restraining the filing of the chargesheet.
The complainant — Shrikant Ojha — challenged this order before the Supreme Court, arguing that the High Court had gravely misconstrued the law and was preventing police from completing their statutory duties.
The Supreme Court’s Ruling: Setting the Record Straight
MISREADING THE PRADNYA PRANJAL KULKARNI JUDGEMENT
One of the Supreme Court’s most significant findings was that the Allahabad High Court had fundamentally misread the Pradnya Pranjal Kulkarni judgment. The apex court clarified that this precedent was not about staying chargesheets — it was about the jurisdictional boundary between Article 226 writ powers and Section 528 BNSS (the equivalent of Section 482 CrPC) once a magistrate takes cognizance of an offence.
The correct legal position, as distilled from Pradnya Pranjal Kulkarni, is as follows: a High Court may quash an FIR under Article 226 as long as cognizance has not been taken. Once a magistrate takes cognizance, the remedy shifts to Section 528 BNSS — which can be used to quash the FIR, the chargesheet, and even the cognizance order, if a strong case is made out. The judgment was never intended as authority for restraining the police from filing a chargesheet in the first place.
REAFFIRMING THE NEEHARIKA INFRASTRUCTURE PRINCIPLES
The Supreme Court also invoked its celebrated five-judge decision in Neeharika Infrastructure (P) Ltd. v. State of Maharashtra (2021), which categorically condemned blanket interim orders passed by High Courts that impede police investigation. A direction not to file a chargesheet, the Court held, is manifestly worse than a blanket “no coercive steps” order — it directly nullifies the statutory duty of the police under the BNSS.
“The direction not to file the chargesheet in reference to the judgment in the case of Pradnya Pranjal Kulkarni is wholly unjust as the facts are completely on different footing.”— Supreme Court of India, J.K. Maheshwari, J. (May 12, 2026)
Accordingly, the High Court’s interim direction staying the filing of the chargesheet was set aside, and the Investigating Officer was directed to complete the investigation and file the police report under Section 193(3) of the BNSS in connection with FIR No. 642 of 2025.
The SIT Order: A Broader Intervention for Rule of Law
Beyond setting aside the High Court’s order, the Supreme Court took an extraordinary step — one rarely seen in matters arising from interim orders — by directing the constitution of a Special Investigation Team to comprehensively probe the fraudulent alienation of the SRMFI’s properties.
Drawing inspiration from its earlier ruling in Pratibha Manchanda & Anr. v. State of Haryana (2023) — which had flagged the menace of land mafias and the need for unimpaired investigation — the apex court issued detailed directions:
Key SIT Directions from the Supreme Court
- SIT to be constituted under the supervision of the Chief Secretary, Uttar Pradesh
- The Registrar of Societies, UP shall be a member — to identify all lands belonging to the SRMFI
- SIT to investigate how lands were alienated or transferred to third parties without the society’s permission
- A fact-finding inquiry to cover all lands sold by persons other than legitimate office bearers
- SIT to submit its report to the concerned police within three months
- Based on SIT findings, cognizance to be taken if acts are found to be fraudulent and criminal in nature
- No coercive action against Respondent No. 2 until SIT submits its report and investigation is completed
- All accused persons must cooperate with the SIT and the investigation
- SIT report to be shared with the High Court for its decision in the pending writ petition.
Why This Judgment Matters: Legal and Social Significance
ON THE LIMITS OF HIGH COURT DISCRETION UNDER ARTICLE 226
This case provides an important corrective to a trend of High Courts using interim protection in FIR-quashing petitions to effectively freeze police investigations. The Supreme Court drew a clear line: while courts may stay arrests and coercive steps during investigation, they cannot direct investigating agencies to withhold their statutory report from the competent magistrate. Doing so usurps the magistrate’s jurisdiction to decide independently whether to take cognizance of an offence.
ON THE CIVIL – CRIMINAL OVERLAP
The High Court’s reasoning — that a civil dispute precludes criminality — was also implicitly rejected. The Supreme Court’s analysis makes clear that the parallel pendency of civil suits (such as declarations about the validity of sale deeds) does not automatically convert a dispute into a purely civil matter. Where forgery, cheating, and misrepresentation form the core of a transaction, the criminal law has an independent and equally valid role to play.
ON PROTECTING SOCIETY’S INSTITUTIONAL PROPERTY
At a broader level, the Court’s concern was palpably human. It noted that Maharishi Mahesh Yogi had never intended for disputes over society management to devolve into asset-stripping. Properties built for spiritual upliftment and public benefit were allegedly being sold off — repeatedly, brazenly, across multiple states — by unauthorized persons exploiting a leadership vacuum. The SIT order reflects the Supreme Court’s recognition that ordinary criminal investigation, fragmented across several police stations, was insufficient to address a coordinated fraud of this scale.
Conclusion: A Judgement That Sends a Clear Message
The Supreme Court’s decision in Shrikant Ojha v. State of UP & Ors. (2026 INSC 482) is significant on multiple fronts. It reinforces the constitutional and statutory limits on High Court powers to restrain investigation; it correctly reads the scope of the Pradnya Pranjal Kulkarni precedent; and it demonstrates the apex court’s readiness to invoke supervisory powers when institutional legacies and the rule of law are simultaneously under threat.
For legal practitioners, the judgment offers a timely reminder: interim relief in FIR-quashing petitions cannot travel so far as to prevent the police from performing their most fundamental duty — placing their investigation report before a magistrate. For the SRMFI and its stakeholders, the SIT order offers the prospect of a comprehensive, unbiased, and time-bound investigation into years of alleged land fraud.
And for those who believe in the rule of law, this case is a reminder that no dispute — however complex, however litigated, however entangled in civil and criminal proceedings across multiple states — is beyond the reach of justice.
