Kiran Raj

The Supreme Court of India Division Bench of Justice Sudhanshu Dhulia and Justice Aravind Kumar has quashed criminal proceedings initiated against five individuals, including two national-level badminton players, a reputed coach, and their family members. The Court held that the continuation of proceedings would constitute an abuse of process, as the allegations lacked prima facie merit and were rooted in vindictive motives. The bench allowed the appeals and set aside the High Court's refusal to quash the FIR and related proceedings. All criminal proceedings arising from FIR No. 194/2022, including P.C.R. No. 14448/2022, were quashed.

The matter stemmed from a complaint filed on 27 June 2022 by Shri Nagaraja M.G. before the Police Inspector, High Grounds Police Station, Bengaluru. The complaint alleged that two individuals had misrepresented their dates of birth to participate in age-restricted badminton tournaments (Under-13 and Under-15 categories), thereby gaining unfair selection and benefits. It was further alleged that their parents and coach conspired to fabricate and falsify records in support of these claims.

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Upon the complaint receiving no immediate response from the police, the complainant filed a private complaint under Section 200 Cr.P.C. before the VIII Additional Chief Metropolitan Magistrate, Bengaluru. This was registered as P.C.R. No. 14448/2022. On 16 November 2022, the Magistrate ordered 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 1 December 2022. The FIR invoked Sections 420, 468, 471, and 34 of the Indian Penal Code, 1860.

The appellants included: Chirag Sen, aged 26; Nirmala Dhirendra Sen, aged 57; Lakshya Sen, aged 23; U. Vimal Kumar, aged 63, a national badminton coach and director of Prakash Padukone Badminton Academy (PPBA); Dhirendra Kumar Sen, aged 62.

Challenging the FIR and the magistrate's order, the appellants filed three separate writ petitions before the High Court of Karnataka: W.P. No. 25699/2022 (Lakshya Sen and U. Vimal Kumar); W.P. No. 26156/2022 (Chirag Sen and Nirmala Sen); W.P. No. 26136/2022 (Dhirendra Sen).

The appellants contended that the same allegations had been examined and dismissed nearly a decade earlier by statutory authorities such as the Sports Authority of India (SAI), the Central Vigilance Commission (CVC), and the Education Department of Karnataka. The CVC, in an Office Memorandum dated 6 February 2018, concluded that the birth certificate and 10th class certificate were final, prompting SAI to close the case against the appellants.

Despite these administrative closures, the respondent initiated fresh criminal proceedings after an eight-year hiatus. The appellants sought quashing on the basis that the proceedings were vexatious and lacked legal substance.

On 19 February 2025, the High Court dismissed all three writ petitions. It held that the documents submitted with the complaint and obtained under the Right to Information Act, 2005, justified an investigation. The High Court maintained that prior administrative inquiries did not bar criminal prosecution if the allegations warranted investigation into cognizable offences.

The appellants then approached the Supreme Court, arguing that the FIR was driven by personal animus and was devoid of any admissible or credible evidence. They pointed to a 1996 GPF nomination form relied upon by the complainant, asserting that it was unauthenticated and unrelated to the individuals accused. They also stated that their dates of birth were supported by statutory documentation and validated by medical boards through biological testing. Further, they contended that continuing the proceedings despite exoneration by specialist authorities like SAI and CVC would prejudice their sporting careers and undermine institutional findings.

The respondent, in opposition, maintained that the 1996 GPF form indicated prior knowledge of different birth dates within the family and that its correctness warranted investigation. He contended that institutional closure did not preclude criminal inquiry and argued that the players might have gained eligibility benefits through altered records.

The Supreme Court began by stating "We are of the firm view that the present case falls squarely within the category of exceptional circumstances warranting interference at the threshold to prevent abuse of the criminal process."

It found that the allegations were based on a single document, the 1996 GPF form, which was not authenticated and did not directly implicate any of the appellants. The Court noted "The said form, even if assumed to be genuine, does not override the birth certificates issued by statutory authorities, nor does it constitute proof of any falsification on the part of appellant Nos.1 and 3 themselves."

It further recorded that "the complainant has neither challenged the validity of the official birth records before any civil forum nor offered any explanation as to why the alleged discrepancies were not raised contemporaneously."

The bench commented on the motive behind the complaint, stating "The undisputed timeline indicates that the complainant’s grievances commenced only after his daughter was denied admission to the academy in 2020."

Addressing the relevance of prior administrative inquiries, the Court held "While the conclusion of administrative bodies is not conclusive for criminal liability, they do bear relevance when evaluating whether a complaint discloses prima facie grounds to proceed further."

Regarding the applicable IPC provisions, the Court stated "There is no allegation that any of the appellants forged or fabricated a document, or that they knowingly used a forged document as genuine."

It found no evidence of wrongful gain or inducement under Section 420 IPC, noting that "Even taking the said form at face value, it is neither demonstrated how the players—who were minors at the time—or their coach had any role in its preparation, nor shown that the document was ever used to obtain a benefit under false pretence."

When questioned by the Court, "no satisfactory explanation was offered" by the respondent's counsel regarding the appellants' involvement in any culpable act.

Citing Pepsi Foods Ltd. v. Special Judicial Magistrate, the bench observed "Summoning an accused in a criminal proceeding is a serious matter and should not be undertaken lightly."

The Court concluded that "To compel such individuals who have maintained an unblemished record and brought distinction to the country...to undergo the ordeal of a criminal trial in the absence of prima facie material would not subserve the ends of justice."

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The Supreme Court allowed the appeals and set aside the judgment of the High Court dated 19 February 2025 in W.P. Nos. 26156/2022, 25699/2022, and 26136/2022.

It held that "FIR No. 194/2022 dated 01.12.2022 registered by High Grounds Police Station, Bengaluru, and all further proceedings in pursuance thereof, including P.C.R. No. 14448/2022, stand quashed."

The bench further directed that "Pending applications, if any, are disposed of. There shall be no order as to costs."

Advocates Representing the Parties:

For the Petitioners: Mr. C.A. Sundram, Sr. Adv. Ms. Rohini Musa, AOR Mr. Badri Vishal, Adv. Mr. Ayush Negi, Adv.

For the Respondents: Mr. Vikram Hegde, AOR; Mr. Abhishek Wadiyar, Adv. 

Case Title: Chirag Sen and Another Etc. v. State of Karnataka and Another

Neutral Citation: 2025 INSC 903

Case Number: Criminal Appeal No. [To be numbered] of 2025 (@ Special Leave Petition (Crl.) Diary No. 9824 of 2025)

Bench: Justice Sudhanshu Dhulia, Justice Aravind Kumar