The Supreme Court quashed the FIR, ruling the allegations of forgery and cheating did not disclose the essential ingredients of Sections 420, 468, or 471 IPC. It held that continuing the prosecution, after prior exoneration by competent authorities without new evidence, constituted a clear abuse of the legal process.
Facts Of The Case:
In 2022, a private complaint was filed by Nagaraja M.G. alleging that badminton players Chirag Sen and Lakshya Sen, their parents, and their coach, Vimal Kumar, had conspired to falsify the players’ dates of birth to gain illegal entry into age-restricted tournaments. The complaint was based primarily on an alleged 1996 GPF nomination form. Following a magistrate’s order under Section 156(3) of the CrPC, the Bengaluru Police registered an FIR for offences including cheating (Section 420 IPC) and forgery (Sections 468 & 471 IPC). This prompted the accused to file writ petitions before the Karnataka High Court seeking to quash the proceedings. They argued that identical allegations had been thoroughly investigated and conclusively closed nearly a decade earlier by competent authorities like the Sports Authority of India (SAI) and the Central Vigilance Commission (CVC), which had verified the authenticity of the players’ official birth certificates and medical age tests. The High Court dismissed their petitions, prompting an appeal to the Supreme Court.
Procedural History:
The procedural history of this case commenced with a private complaint filed under Section 200 Cr.P.C. before the VIII Additional Chief Metropolitan Magistrate, Bengaluru. The Magistrate, by an order dated 16.11.2022, directed an investigation under Section 156(3) Cr.P.C., leading to the registration of FIR No. 194/2022 by the High Grounds Police Station on 01.12.2022. Challenging this FIR and the magistrate’s order, the appellants filed three separate writ petitions under Articles 226 and 227 of the Constitution read with Section 482 Cr.P.C. before the High Court of Karnataka. In a common judgment dated 19.02.2025, the High Court dismissed all writ petitions, declining to quash the proceedings. This dismissal led to the filing of Special Leave Petitions before the Supreme Court, which granted leave and, upon hearing the appeals, allowed them and quashed all proceedings.
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Court Observation:
The Court observed that the entire case was built on an unauthenticated and unreliable document—a 1996 GPF nomination form—which failed to establish any fraudulent intent or act by the appellants. It held that the allegations, even if taken at their highest, did not disclose the essential ingredients of the offences of cheating (Section 420 IPC) or forgery (Sections 468 & 471 IPC), as there was no evidence of dishonest inducement, wrongful gain, or the use of a forged document as genuine. The Bench strongly noted that the complaint was permeated with vindictiveness, initiated years after multiple competent authorities like the SAI and CVC had already examined and closed the matter, finding no discrepancy in the official birth records. The Court ruled that continuing the criminal prosecution in the absence of prima facie material and after prior institutional exoneration amounted to a gross abuse of the process of law.
Final Decision & Judgement:
The Supreme Court allowed the appeals and set aside the impugned judgment of the High Court of Karnataka. Consequently, it quashed FIR No. 194/2022 registered by the High Grounds Police Station, Bengaluru, and all ensuing proceedings, including P.C.R. No. 14448/2022. The Court held that the continuation of the criminal prosecution in the absence of any prima facie material to constitute the alleged offences and after prior exoneration by competent authorities amounted to a gross abuse of the process of law.
Case Details:
Case Title: Chirag Sen and Another etc. Versus State of Karnataka and Another Citation: [2025] INSC 903 Date of Judgement: July 28, 2025 Judges/Justice Name: Justice Sudhanshu Dhulia and Justice Aravind Kumar
Download The Judgement Here