Panaji: The Bombay High Court at Goa has quashed an FIR, chargesheet, and criminal proceedings against actor-turned-social activist Gaurav Bakshi, observing that merely telling a public servant that he would approach vigilance authorities or lodge a complaint could not, by itself, amount to criminal intimidation.
Justice Amit S. Jamsandekar, in an order pronounced on August 18, quashed the FIR registered at the Panaji Police Station, the chargesheet filed in the case, and the subsequent criminal proceedings before the Judicial Magistrate First Class (JMFC) at Merces.
The FIR was registered on December 12, 2025, under Sections 132, 352, and 351(3) of the Bharatiya Nyaya Sanhita (BNS), based on a complaint filed by an official of the Mamlatdar’s office at Tiswadi. Bakshi was accused of abusing the official, threatening him, and creating a disturbance at the office while the official was discharging his duties in connection with a land-conversion file.
The prosecution alleged that Bakshi had threatened the official by saying, among other things, “I will show you” and “I will see that you lose your job by registering a vigilance case against you.”
However, the High Court held that even if all the allegations in the complaint were accepted in their entirety, they did not disclose any threat of physical injury, injury to reputation, or injury to property. It further observed that there was no allegation that the complainant was put in a state of sudden fear or apprehension of immediate danger to his person, reputation, or property.
The court specifically held that the threat to approach vigilance authorities or lodge a complaint could not, by itself, amount to criminal intimidation under Section 351(3) of the BNS.
“A person informing another that he would take recourse to a lawful remedy cannot be treated as threatening that person with injury within the meaning of Section 351(3) of the BNS,” the court observed.
The High Court also noted that the prosecution relied on allegations that Bakshi had disturbed the peaceful functioning of the office and obstructed the official in discharging his duties. However, it observed that merely using rude or abusive words, or engaging in an argument, could not automatically result in criminal liability unless the statutory ingredients of the particular offence were satisfied.
On the charge under Section 132 of the BNS, the court considered the allegation of assault or criminal force against a public servant. The record, as noted in the order, contained no allegation of pushing, touching, catching hold of, manhandling, or any other physical act against the complainant. The allegations essentially concerned an exchange of words, abusive language, and the threat to approach vigilance authorities.
The court also took note of the chronology of events. Bakshi had earlier filed a complaint on February 6, 2025, against the official, alleging dereliction of duty and harassment and seeking disciplinary action. The official subsequently lodged the FIR against Bakshi on December 12, 2025.
The High Court said the earlier complaint provided “the necessary background” to the prosecution and that the FIR could not be viewed in isolation. The court accepted the submissions made on behalf of Bakshi and rejected those advanced by the state.
The court concluded that continuing the criminal proceedings would be unfair and contrary to the interests of justice and would amount to an abuse of the process of law.
It accordingly quashed the FIR, chargesheet, the March 9, 2026, order of the JMFC taking cognisance and issuing process, as well as all further and consequential proceedings arising from the case.
