Case Details

  • Case Name: Rushikesh Bhatt vs. State of Madhya Pradesh
  • Court/Authority: Supreme Court of India, Criminal Appellate Jurisdiction
  • Case/Order No.: Criminal Appeal No. /2026 @ SLP (CRL) No.7814/2025
  • Date of Order: 19 May 2026
  • Period of Alleged Violation: Business transaction in 2021; FIR registered on 2025 (FIR No.33/2025)

Parties Involved

  • Appellant: Rushikesh Bhatt
  • Respondent: State of Madhya Pradesh
  • Complainant: Aditya Narayan Godbole, operating Vyadeshwar Export Private Limited (logistics, import‑export business)
  • Investigating Officer (IO): Not named
  • Trial Court: Lower court that initially denied anticipatory bail
  • High Court: Madhya Pradesh High Court, Indore (MCRC No.4664/2025)
  • Counsel for Petitioner: Mr. Siddharath Dave (Senior Advocate), Mr. Krunal Saxena, Mr. Amogh Bansal, Aura & Co.
  • Counsel for Respondent: Mr. Sarthak Raizada, Mr. Pushpinder Singh, Mr. Pashupathi Nath Razdan
  • Justices: Hon'ble Mr. Justice Aravind Kumar, Hon'ble Mr. Justice Prasanna B. Varale

Issues / Allegations / Violations

  • The complainant alleged that Bhatt, claiming to manufacture Sodium Acetate Trihydrate, entered into an agreement to supply ten containers of the chemical for Rs 53,05,300.
  • The complainant paid Rs 58,00,000 via online bank transfer.
  • Bhatt allegedly dispatched only a few containers, with a shortage of material and the supplied chemical containing only 0.93% Sodium Acetate Trihydrate instead of the agreed 99% purity.
  • Cheques issued by Bhatt were dishonoured for insufficient funds and overwriting.
  • The FIR (No.33/2025) charged Bhatt under IPC Sections 406 (criminal breach of trust), 409 (dishonest misappropriation), and 420 (cheating).
  • The appellant sought anticipatory bail; the trial court rejected, and the High Court upheld the rejection.

Findings & Observations

  • The Court observed that the dispute over the exact quantity and quality of the chemical is a business‑transaction matter that requires factual examination by the trial court.
  • Purity issues are to be established through test reports, which are evidentiary matters.
  • The Supreme Court noted that an interim protection order dated 19.05.2025 had already been granted, directing Bhatt to cooperate with the investigation.
  • While Bhatt appeared before the IO, the Court found his responses evasive but not constituting a mischief of non‑cooperation.
  • The Court concluded that the interim protection could be made absolute, allowing anticipatory bail on suitable terms.

Penalties / Settlements / Directions

  • The Supreme Court set aside the impugned order of the High Court.
  • It directed the Investigating Officer to grant anticipatory bail to Rushikesh Bhatt on such terms and conditions as deemed fit, including:
  • Mandatory appearance before the IO whenever called.
  • Mandatory appearance before the trial court on all hearing dates, unless exempted.

Corrective Actions & Future Obligations

  • Bhatt must cooperate fully with the Investigating Officer and comply with any conditions imposed for the anticipatory bail.
  • He must appear before the trial court for every hearing date, except when a lawful exemption is granted.

Final Ruling & Enforcement

  • The Supreme Court allowed the criminal appeal, set aside the earlier order, and ordered anticipatory bail with the conditions above.
  • All pending applications in the matter were ordered disposed of.
  • The order was signed by Justices Aravind Kumar and Prasanna B. Varale on 19 May 2026.