Nagpur: Resisting one’s medical examination does not amount to voluntarily obstructing a public servant in the discharge of official duty under Section 186 of Indian Penal Code, Supreme Court held while quashing criminal proceedings against an Amravati forest department employee.
Section 186 IPC is applied if someone voluntarily prevents or interferes with a govt/public servant while s/he is carrying out their lawful duties. A division bench comprising Justices KV Viswanathan and Arun Palli allowed a woman’s appeal on Aug 12 and set aside the Nov 19, 2025, order of Nagpur bench of Bombay High Court, which had declined to quash the proceedings arising from a 2021 FIR. The case stemmed from an FIR registered at Achalpur police station on May 4, 2021, under Sections 186 and 189 IPC and Sections 110, 112 and 117 of Maharashtra Police Act. The apex court said the allegation, even if accepted, did not constitute the offence under Section 186 IPC. The judges also questioned the applicability of Sections 110, 112 and 117 of Maharashtra Police Act. “Section 110 prohibits use of indecent language or indecent behaviour in a disorderly manner in public places, including streets, public offices, stations and station houses. Section 112 deals with the use of threatening, abusive or insulting words or behaviour intended to provoke a breach of peace or likely to cause one. Section 117 provides for punishment for violations of the provisions covered under Sections 99 to 116,” the judges said.
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The court added that it was “at a loss to understand” how Maharashtra Police Act provisions were applicable. The consequential chargesheet was also challenged. As per the FIR, the woman, the then Lekhapal at Forest Range Office, Paratwada, was allegedly found intoxicated and creating a ruckus. The prosecution alleged that she resisted medical examination at the sub-district hospital, Achalpur, and created a scene. She was subsequently persuaded and underwent the examination. The bench held that, even taking the prosecution case at its highest, the alleged offences were not made out. Download the TOI App.
Court Ruling Clarifies Legal Definitions Regarding Public Servants
The court clarified that the actions attributed to the petitioner do not fall under the definition of ‘voluntarily obstructing any public servant in the discharge of his public function.’ This ruling was made in light of the fact that the petitioner ultimately complied with a medical examination. Additionally, the court determined that Section 189 of the Indian Penal Code (IPC), which addresses the act of threatening a public servant to influence their official duties, was not applicable in this case.