Tejashwi Prasad Yadav vs. Hareshbhai Pranshankar Mehta [February 13, 2024]
Background
The case arose from a criminal defamation complaint filed against Tejashwi Prasad Yadav, then Deputy Chief Minister of Bihar, for allegedly defaming the entire Gujarati community. The complaint, filed in the Ahmedabad Court of the Additional Chief Metropolitan Magistrate, was based on Yadav’s public statement on March 22, 2023, in which he referred to all Gujaratis as “thugs.” The complainant argued that this statement damaged the reputation of Gujaratis, causing them to be perceived as “crooks and criminals” by others.
Key Legal Issues
Whether the criminal defamation case (under Sections 499 and 500 IPC) should be quashed after the petitioner’s unconditional withdrawal of the allegedly defamatory statement.
Whether the prosecution should continue in light of the petitioner’s clarification and apology.
Whether the request to transfer the case from Ahmedabad to Delhi survived after the substantive issue was addressed.
Supreme Court’s Analysis
The Supreme Court noted that Yadav had filed affidavits clarifying that his statement was made in the specific context of questions relating to the revocation of a Red Corner notice against Mehul Choksi and that he never intended to defame the Gujarati community. He expressly stated that he held Gujaratis in high esteem and withdrew the offending statement unconditionally.
The Court observed that, ordinarily, the withdrawal of a defamatory statement alone is not sufficient ground to quash a criminal defamation prosecution. However, in this case, the Court found that Yadav not only withdrew his statement but also explained the circumstances and context, making it clear that there was no intention to defame.
The Court emphasized that continuing the prosecution would serve no purpose and would be unjust in the peculiar facts of the case. The exercise of its powers under Article 142 of the Constitution was deemed appropriate to do complete justice between the parties.
As the complaint was quashed, the prayer for transfer of the case from Ahmedabad to Delhi became infructuous.
Judgment
The Supreme Court quashed the criminal defamation case pending before the Additional Chief Metropolitan Magistrate, Ahmedabad, against Tejashwi Prasad Yadav.
The Court’s decision was based on the unconditional withdrawal of the statement, the petitioner’s clarification of intent, and the absence of any continuing ill will towards the Gujarati community.
The petition for transfer was disposed of as it no longer survived.
Significance
This judgment underscores the Supreme Court’s balanced approach in defamation cases involving public figures, recognizing the importance of both freedom of speech and protection of community reputation. It also highlights the Court’s willingness to exercise its extraordinary powers under Article 142 to do complete justice in cases where prosecution would be unjust or purposeless.
Citation:
Tejashwi Prasad Yadav v. Hareshbhai Pranshankar Mehta, 2024 INSC 108, Supreme Court of India, decided on February 13, 2024.
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