Madhya Pradesh High Court quashes sham FIR against Jodhaa Akbar film editor Dilip Deo, ruling he was lured and arrested unlawfully, and orders Rs 5 lakh compensation.
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MADHYA PRADESH: Madhya Pradesh High Court has quashed criminal proceedings against Bollywood film editor Dilip Deo, observing that the FIR registered against him was nothing but a sham, lodged with mala fide intention to extort money.
Background of the Case
Dilip Deo, acclaimed for his editing work in blockbuster films like Jodhaa Akbar and Wanted, was arrested by the Ujjain police on January 5, 2016, on allegations of criminal intimidation and fraud linked to a film promotion agreement gone wrong. His arrest sparked controversy as he was taken into custody in Mumbai, allegedly without prior intimation to the local police.
Shockingly, the Ujjain police team allegedly lured Deo under the pretext of a film editing contract and then arrested him using a private car. According to Mumbai Police records, Deo was even taken to his Goregaon residence, where his wife was forced to sign a cheque worth Rs 10 lakh at the insistence of the Ujjain police team.
Court’s Observations
Justice Subodh Abhyankar of the Madhya Pradesh High Court found several glaring irregularities in the case:
- The FIR was filed under Section 66A of the Information Technology Act, 2000, a provision that had already been struck down by the Supreme Court in Shreya Singhal v. Union of India (2015).
- Section 507 of the IPC (criminal intimidation by anonymous communication) was wrongly invoked since the calls were not anonymous.
- The FIR and subsequent police report under Sections 507, 506B, 406, 420, and 34 IPC made no mention of any monetary transaction involving the complainant and the accused.
The Court went on to declare the FIR a “sham” and concluded that the entire case bore the trappings of a civil dispute rather than a criminal matter.
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The case also highlighted questionable police conduct. It was revealed that the Ujjain police wrongfully obtained a cheque of Rs 10 lakh from Deo’s wife during his arrest. Departmental proceedings were later initiated against multiple officers, including Inspector R.K. Singh, then SHO of Birlagram, Nagda, for sending a team to Mumbai without authorization. His reply was found unsatisfactory, and one increment was withheld with cumulative effect as punishment.
The High Court ordered the State of Madhya Pradesh to pay exemplary costs of Rs 5 lakh to Deo within one month. Importantly, the State was granted liberty to recover the compensation amount from the delinquent police officers and the complainant, per the law.
Deo had also earlier received interim relief of Rs 25,000 awarded by the Human Rights Commission to his wife for harassment caused during the incident.
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The false case caused significant damage to Deo’s reputation. In his petition, he claimed that people began avoiding him and stopped offering him work, leaving him in a financially strained “hand-to-mouth” situation.
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