Bombay High Court

RAVINDRA LAXMAN BARHATEversusINSPECTOR CRIME AND ORS

Decided: 17 February 2026
Disposal: Dismissed
Bench: A S GADKARI SHYAM C CHANDAK

Holding

The petition is dismissed as an abuse of process because the filing does not qualify as a complaint under Section 154(1) CrPC.

Summary

Petitioner Ravindra Laxman Barhate, claiming to be a Right to Information activist, filed a complaint on 29 August 2013 on behalf of alleged victims, addressing various authorities including revenue departments. The High Court examined whether this complaint qualified as a "complaint" under Section 154(1) of the Criminal Procedure Code. It held that the victims themselves had not lodged any grievance and the petitioner was merely attempting to champion their cause without legal standing. Consequently, the Court found the petition to be an abuse of the legal process. The petition was therefore dismissed.

Issues considered

Whether the petitioner's filing constitutes a complaint within the meaning of Section 154(1) of the Criminal Procedure Code
Whether the petition is maintainable or amounts to an abuse of process of law

Legislation cited

Code of Criminal Procedure, 1973 — s. 154(1)

Subjects

abuse of process
Section 154 CrPC
complaint
Right to Information activist
criminal writ petition
maintainability

Judgment

HEMANT
CHANDERSEN
SHIV
                           H.C. SHIV                                                   8.w936.14.doc
Digitally signed by
HEMANT
CHANDERSEN SHIV
Date: 2026.02.24                       IN THE HIGH COURT OF JUDICATURE AT BOMBAY
18:32:51 +0300
                                             CRIMINAL APPELLATE JURISDICTION

                                         CRIMINAL WRIT PETITION NO.936 OF 2014


                      Ravindra Laxman Barhate                 …..Petitioner
                            Vs.
                      Senior Inspector Crime,
                      Bund Garden Police Station
                      Pune & Ors.                             …..Respondents
                                    __________________________________________

                      Mr. Sachindra B. Shetye, Advocate with Mr. Akshay Pansare, i/b Manish R.
                      Bohra for the Petitioner.
                      Mr. Ashish I. Satpute, APP for the Respondent-State.
                      Mr. Dormaan Dalal, Advocate for Respondent Nos.4 and 5.
                      Mr. A. S. Chougule, API, Bundgarden Police Station, Pune City present.
                                     __________________________________________

                                                         CORAM :      A. S. GADKARI AND
                                                                      SHYAM C. CHANDAK, JJ.
                                                            DATE :    17th FEBRUARY, 2026.


                      P.C.:-

                      1)               Petitioner claims to be the right to information activist and on

                      behalf of the victims, had filed alleged complaint dated 29 th August, 2013.

                      Perusal of the said complaint prima facie indicates that, it was addressed to

                      various Authorities including the Revenue Authorities.

                      2)               We are of the view that the said complaint is not a complaint as

                      contemplated under Section 154(1) of the Cr. P. C.           The victims of the

                      alleged crime did not make any grievance about the said forgery.                 The

                      Petitioner claiming to be their savior and/or leader under the pretext or



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     H.C. SHIV                                                    8.w936.14.doc

claiming to be right to information activist, is allegedly trying to espouse

their cause. According to us, it is not permissible in law.

3)               In our considered view, Petition is sheer abuse of process of

law and is accordingly dismissed.



         (SHYAM C. CHANDAK, J.)                        (A.S. GADKARI, J.)




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