The Patna High Court has quashed criminal proceedings against Juggernaut Books Pvt. Ltd., the publisher of the book Godman to Tycoon: The Untold Story of Swami Ramdev, holding that a follower or disciple cannot maintain a defamation complaint merely because they are aggrieved by statements made about their spiritual leader.
Justice Alok Kumar Sinha passed the judgment on November 3, 2026, while allowing a petition filed by the publishing company under Section 482 of the Code of Criminal Procedure. The company had challenged orders passed by the Additional Chief Judicial Magistrate-II, Hajipur, in 2017, taking cognizance of offences under Sections 295-A, 500, 501 and 502 of the Indian Penal Code.
The complaint was filed by a follower of Swami Ramdev. He alleged that the book portrayed Ramdev in a defamatory manner, indirectly held him responsible for the deaths of Guru Shankaranand, Swami Yogananda and Rajiv Dixit, and contained statements that hurt religious sentiments, including references to Ramdev’s background and his wearing of gerua vastra.
The Publisher argued that the complainant was not the person allegedly defamed and could not institute criminal defamation proceedings on behalf of Swami Ramdev. He relied on Section 199(1) CrPC, which requires a complaint by a person aggrieved by the alleged defamation. He also argued that cognizance under Section 295-A IPC had been taken without the mandatory prior sanction of the government.
Accepting these submissions, the High Court held that the complainant did not qualify as a “person aggrieved” under Section 199(1) CrPC. It observed that the alleged imputations in the book were directed against Swami Ramdev and not against his followers as a class. The Court observed:
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“The complainant cannot, therefore, step into the position of the person allegedly defamed merely because he is a disciple or a follower of that person. The statutory requirement under Section 199(1) cannot be enlarged on the basis of personal sentiments or association. The law requires that the complainant must be a ‘person aggrieved’ by the alleged offence.”
The Court further held that cognizance under Section 295-A IPC could not have been taken without prior sanction under Section 196(1)(a) CrPC. It noted that the record did not show that such sanction had been obtained.
It also found that the complaint did not identify any specific religious belief allegedly insulted by the book or disclose the deliberate and malicious intention required to constitute an offence under Section 295-A IPC. Merely alleging that the contents had hurt the sentiments of Ramdev’s followers was insufficient.
The High Court, however, rejected the publisher’s contention that there had been no inquiry under Section 202 CrPC, observing that the Magistrate’s examination of the complainant and other witnesses could constitute the inquiry contemplated under the provision.
Holding that the prosecution suffered from fundamental legal infirmities, the Court quashed the Magistrate’s orders dated October 7 and 9, 2017, along with all consequential criminal proceedings against the publisher.
