Complaint filed with SHO, Bajaj Nagar, Jaipur against Narendra Modi for hate speech

Jan 01, 1970
By Kavita Srivastava, Bhanwar Meghwanshi

Bajaj Nagar Thana,


Biju George Joseph
Commissioner Police, Jaipur


Subject:      Immediate registration of FIR and strict action against Shri Narendra Modi, the Prime Minister, for committing grave criminal offences under Sections 153A, 153B, 295 (A), 505 (1) and 505 (2) of the Indian Penal Code, 1860 by making communal hate speech in Banswara, Rajasthan, on April 21, 2024. (Along with the sections of the  Model Code of Conduct and Sections 123(3) and (3A), 125 of the Representation of the People Act, 1951)


I  am filing this criminal complaint as a concerned citizen of this country, on my own free will and in my personal capacity. I am  not affiliated to any political party. I am committed to the rule of law and the Constitution of India. 

As you know the nation is currently involved in the 2024 Lok Sabha elections and the Model Code of Conduct (MCC) is in place. All candidates and representatives of political parties campaigning for the elections are supposed to strictly conform to the MCC to the hilt and the provisions of the Representation of People’s Act.

Through this complaint, I wish to bring to your notice the hate speech publicly made by Shri Narendra Modi, the Prime Minister, in an election meeting at the college grounds in Banswara city, on April 21, 2024, at about 5 pm in Rajasthan. This Sabha was called the Vijay Shankhnaad Sabha. In this sabha the candidates from two Lok Sabha constituencies, Mahendrajeet Singh Malviya (Banswara Parliamentary Constituency), Dr. Manna Lal Rawat (Udaipur Parliamentary Constituency), State BJP President CP Joshi along with many BJP party leaders were present on stage.

This speech falls squarely within the purview of hate speech as defined under section 153 (A) and section 295 (A) of 505 (1) (b), (c) 505 (2) of the Indian Penal Code. A link to the video of this speech is available at the link with the title “PM Modi Live | Public meeting in Banswara, Rajasthan | Lok Sabha Election 2024”.

The hate speech has been widely circulated and covered in the media and has reached far and wide across the country. Having been made from the highest office of the nation, it is bound to have serious and lasting repercussions, apart from influencing the election on divisive and communal lines

I happened to see the entire speech of Shri. Narendra Modi in the social media late in the evening of 21st April, 2024 and was shocked by the speech which was clearly aimed to promote enmity between Hindus and Muslims thereby promoting on grounds of religion and community, disharmony or feelings of enmity, hatred or ill-will between members of Hindu and Muslim community. I have downloaded the said speech from the YouTube site on to a Thumb Drive today, 22.4.2024, and the same is being submitted to you along with this written complaint.

Anyone watching the entire video, will not be left in any doubt whatsoever that Shri Modi as a star campaigner for the Bharatiya Janata Party (BJP) wishes to cause animosity and hate between the communities.

I urge that the SHO particularly watch the video from 36:02  to 38:01, a Hindi transcript of which, taken from the You Tube link mentioned above itself, is reproduced below.

The content of the hate speech made by Shri Narendra Modi is not only false but is calculated to promote hate and enmity on the grounds of religion and community, disharmony and create feelings of enmity, hatred, or ill will between different religious groups and communities. Moreover, the speech has been made at an election rally to procure votes from the citizens on communal lines.

The speech clearly constitutes acts prejudicial to the maintenance of peace and harmony between different religious groups in Rajasthan and in the country as a whole. Similarly, it should also be noted that the speech of Shri Narendra Modi constitutes deliberate and malicious act intended to outrage religious feelings and adding insults or attempting to insult the religion and the religious beliefs. In a way, Shri Modi’s speech is instigating Hindus against the Muslims by calling them infiltrators.

The speech of Shri Narendra Modi was very clearly made with an intention to cause and in any event is likely to cause, fear or alarm in one community against the other, including the public at large, whereby any person is induced to commit an offence against public tranquillity. It also constitutes incitement and in any event is likely to incite any class or community of persons to commit any offence against the any other class or community.

The video coverage of the meeting also shows Narendra Modi is arousing the public sentiment by very clearly prodding them with the question and in effect goading them to respond to the questions such as “whether such an act of extorting gold and taking away the mangal sutra of women (Hindu) would be acceptable to them?”, to the chorus of the public. And clearly adding that this is what he has come to inform them, implying that he has come to warn them of the dire consequences. 

Please note that the video of the speech made by Shri Modi in Banswara on 21st April, 2024 is freely available at the above URL for downloading. It is also available on Shri Modi’s website at the URL:

The fact that the speech is available in video form for being downloaded freely means that the video will continue to cause greater harm to the relations between Hindus and minority Muslims of Rajasthan, as also India, as a whole.  The fact that the video version of the speech is available free for download in several platforms means that the video will continue to cause greater alarm and fear in the minds of people. 

I would like to point out that given the Constitutional stature of Shri Narendra Modi as the current Prime Minister of India, the hate speech he delivered in Banswara will have a snowballing effect throughout the state of Rajasthan and across India in fostering disharmony and hate towards the minority Muslim community. It should also be noted out that only one phase of the seven phases of the election process is completed and intense electioneering is going on in many parts of India. . Under these circumstances, the speech by Shri Narendra Modi, is an ominous call to his party men and others who nurse prejudice against the Muslim minority community to more vigorously step forward to attack, silence, cause fear and intimidate the minorities. The speech in effect, is meant to provoke  people from the majority community who bear a grudge against the minority community thereby inciting them or encouraging them to attack the minorities, even at a later stage, anywhere in Rajasthan as also the rest of the country.

Very clearly the speech made by Shri Narendra Modi was deliberately delivered to polarise and incite a section of the public at large on majoritarian lines. Therefore, the police needs to intervene immediately and takes appropriate action by registering a case as well as prosecute Sh. Narendra Modi. If no action is taken by the Rajasthan police, then it will not only encourage him to continue with his hate and provocative speeches, but also others in his party and elsewhere will be motivated to emulate their leader’s speech which promotes enmity and hatred against the minority Muslim community.

It is to be noted that following the communal hate speech made on April 21, 2024, there has been overwhelming public protest and outrage in media, social media, including complaints filed with the Election Commission of India against Shri Modi for his speech. This clearly shows the citizen’s anguish against such hateful and discriminatory speech that can break the unity, threaten national interest and damage the social fabric of our country and stands against the values of fraternity, equality and secularism which are an integral part of the Indian Constitution. Accordingly, strict action is required to be taken in accordance with law.

As you must be aware, in the ongoing matter before the Hon’ble Supreme Court of India (Saheen Abdullah versus Union of India, W.P. (C) No.940/2022), in which the State of Rajasthan and DGP, Rajasthan are also parties. In this case,  taking note of the increasing hate speech across the country, the Hon’ble Supreme Court was pleased to issue the below directions against all states to ensure suo moto registration of FIRs against hate speech offenders.

“Respondent Nos. 9 to 36 shall ensure that immediately as and when any speech or any action takes place which attracts offences such as Sections 153A, 153B and 295A and 505 of the IPC etc., suo motu action will be taken to register cases even if no complaint is forthcoming and proceed against the offenders in accordance with law.

Respondent Nos. 9 to 36 will therefore issue direction(s) to their subordinates so that appropriate action in law will be taken at the earliest. We make it clear that any hesitation to act in accordance with this direction will be viewed as contempt of this Court and appropriate action will be taken against the erring officers.

We further make it clear that such action will be taken irrespective of the religion that the maker of the speech or the person who commits such act may profess, so that the secular character of India, that is, Bharat as is envisaged by the Preamble, is preserved and protected.”

It is also clear that the hate speech made in Banswara, Rajasthan and in particular the above excerpts from Shri Narendra Modi’s speech, constitute serious criminal offences under Sections 153A, 153B, 295 (A), 505 (1) and 505 (2) of the Indian Penal Code, 1860. They are also clearly in violation of Sections 123(3), 123(3A), and Section 125 of the Representation of the Peoples Act (RPA), 1951. The RPA, 1951 can be seen at In fact the hate speech constitutes an act against the nation.

I accordingly call upon the police to accept my complaint and register the FIR forthwith against Shri Modi and the organisers of the Vijay Shankhnaad  Sabha, meeting, including the BJP candidates Mahendrajeet Singh Malviya and Dr. Manna Lal Rawat and against CP Joshi, the State BJP President who was present in the meeting and prosecute them in accordance with the law. I urge you to file the FIR under Sections 153A, 153B, 295 (A), 505 (1) and 505 (2) of the Indian Penal Code, 1860 and under Sections 123(3), 123(3A), and Section 125 of the Representation of the Peoples Act (RPA), 1951 and initiate strict action in accordance with law to prosecute the above offenders and any others involved for this serious crime. Given that the general elections are already underway, it is absolutely necessary that the action be taken without any loss of time. 

I further call upon the police to take concrete measures to prevent communal hate speech in the State of Rajasthan, including by taking steps to ensure that strict action is taken in hate speech FIRs, repeated offenders of hate speech are prevented from making public speeches without proper diligence taken to ensure that such crimes are not repeated and any attempts to make hate speech are stopped immediately. I also urgent the police to ensure the protection and safety of Muslims and other minorities from attacks in light of the provocative hate speech made and to ensure peace and harmony in the state of Rajasthan.

Yours sincerely,


Kavita Srivastava

Bhanwar Meghwanshi


[This complaint was then forwarded to the Superintendent of Police, Jaipur. A similar complaint was also filed by PUCL-Rajasthan and Rajasthan Election Watch with the Chief Election Officer, Secretariat, Jaipur.]