Chirag Sen & Ors. V. State of Karnataka & Ors. (2025)

Case Title & Citation

    Case Title: Chirag Sen & Ors. V. State of Karnataka & Ors. (2025)
    Citation: MANU/SC/0990/2025

Court Name & Bench

    Court: Supreme Court of India
    Bench: Division Bench comprising Justice Sudhanshu Dhulia and Justice Aravind Kumar

Date of Judgment

    Date: 28 July 2025

Parties Involved

Appellants:

• Chirag Sen, son of Dhirendra Kumar Sen, aged about 26 years;
• Nirmala Dhirendra Sen, wife of Dhirendra Kumar Sen, aged about 57 years;
• Lakshya Sen, son of Dhirendra Kumar Sen, aged about 23 years;
• Vimal Kumar, son of Unnikrishnan Nair, aged about 63 years; and
• Dhirendra Kumar Sen, son of Late C.L. Sen, aged about 62 years.

Respondents:

• State of Karnataka – Represented by the police authorities
• G. Nagaraja – Private complainant, a rival badminton coach

Facts of the Case

• A complaint was lodged on 27 June 2022 by M.G. Nagaraja (Respondent No. 2), a badminton coach, alleging that Chirag Sen and Lakshya Sen (Appellants 1 and 3) had falsified their dates of birth to gain eligibility for age-restricted badminton tournaments (Under-13 and Under-15).
• It was further alleged that their parents (Appellants 2 and 5) and coach U. Vimal Kumar (Appellant 4) conspired to fabricate official records, such as birth certificates, for wrongful gain and selection.
• The primary evidence cited was a 1996 General Provident Fund (GPF) nomination form, allegedly submitted by their father (Appellant 5), showing different birth years.
• As the police did not register an FIR, the complainant filed a private complaint under Section 200 CrPC, which was registered as P.C.R. No. 14448/2022.
• On 16 November 2022, the Magistrate passed an order under Section 156(3) CrPC, directing a police investigation.
• This led to the registration of FIR No. 194/2022 by the High Grounds Police Station, Bengaluru, under Sections 420, 468, 471, and 34 IPC.
• The appellants filed three separate writ petitions before the High Court of Karnataka under Articles 226/227 of the Constitution and Section 482 CrPC, seeking quashing of the FIR and the Magistrate’s order.
• The petitions were:
• P. No. 25699/2022 – by Lakshya Sen and Vimal Kumar
• P. No. 26156/2022 – by Chirag Sen and Nirmala Sen
• P. No. 26136/2022 – by Dhirendra Kumar Sen
• The appellants contended that the identical allegations had already been thoroughly investigated and dismissed by competent statutory bodies, including:
• Sports Authority of India (SAI)
• Central Vigilance Commission (CVC)
• Education Department, Govt. of Karnataka
• In 2018, the CVC, through an official memorandum, had concluded that birth certificates and 10th class certificates are final for determining age.
• Based on this, SAI had closed the inquiry, and no further action was taken at that time.
• Despite this, the respondent initiated fresh criminal proceedings after nearly eight years, without new evidence.
• On 19 February 2025, the Karnataka High Court dismissed the writ petitions, holding that:
• The complaint disclosed prima facie grounds for investigation.
• Prior administrative closure did not bar a criminal investigation.
• Aggrieved by the High Court’s decision, the appellants approached the Supreme Court of India, asserting that the proceedings were baseless, malicious, and constituted an abuse of the legal process.

Issues Raised

1. Whether the FIR disclosed cognizable offences warranting criminal prosecution.
2. Whether the complaint constituted an abuse of process given the prior administrative clearance.
3. Whether continuation of proceedings against national players was legally sustainable.

Arguments of the Parties

Contentions of the Appellants:

• Senior Advocate Mr. C.A. Sundaram, representing the appellants, argued that the FIR and complaint were clear examples of misuse of the legal process, rooted in personal vendetta rather than genuine legal grievances.
• He pointed out that the entire case was built around a 1996 GPF nomination form, which:
• Was unauthenticated and unverified.
• Had never undergone forensic examination.
• Did not mention Lakshya Sen, who was not even born in 1996, making its relevance questionable.
• The appellants’ birth details were consistently recorded in valid government-issued documents (birth certificates, school records, etc.) that had never been challenged through any legal process.
• The complaint lacked evidence of criminal intent, dishonest inducement, or any fraudulent gain by the appellants.
• Independent medical assessments by multiple boards had confirmed the biological age of the players matched their official documents.
• Prior investigations by SAI, CVC, and BAI had thoroughly looked into the allegations and closed the matter, finding no discrepancies or wrongdoing.
• Allowing such proceedings to continue would unfairly damage the careers and reputation of internationally recognized sportspersons and undermine public faith in institutional mechanisms.
• The High Court’s decision to not quash the FIR, without adequately considering these factors, amounted to a misapplication of its jurisdiction under Article 226 of the Constitution.

Contentions of the Respondents:

• The counsel for Respondent No. 2 argued that the 1996 GPF nomination form indicated that there was prior knowledge in the family of the players’ original birth dates, which were allegedly altered later to obtain age-based advantages.
• It was submitted that the accuracy and authenticity of the GPF form could be verified through investigation, and such scrutiny should not be preemptively blocked.
• The respondent maintained that previous administrative closures (by SAI or CVC) do not prevent a fresh criminal investigation, especially when the allegations concern potential forgery and fraud.
• The medical examinations cited by the appellants were characterized as non-binding or inconclusive for purposes of criminal liability.
• Hence, the respondent urged the Court to allow the investigative process to continue, as it may bring out facts that earlier inquiries may have overlooked, and prayed for the dismissal of the appeals and upholding of the High Court’s order.

Cases Cited:

• Zandu Pharmaceutical Works Ltd. v. Mohd. Sharaful Haque[1]
• State of Haryana v. Bhajan Lal[2]
• Pepsi Foods Ltd. v. Special Judicial Magistrate[3]

 Judgment

• The Supreme Court allowed the appeal.
• It set aside the High Court’s decision.
• The Supreme Court held that the complaint and FIR were motivated by personal vendetta, especially after the complainant’s daughter was denied admission to the PPBA in 2020.
• The sole reliance on an unauthenticated 1996 GPF nomination form was found to be inadequate and irrelevant, especially since Lakshya Sen was not even born in 1996. The form had not been verified or subjected to forensic examination.
• The Court observed that the birth certificates and school records of the appellants had never been challenged and were corroborated by medical age assessments conducted by government hospitals, including AIIMS.
• It noted that prior inquiries by institutions such as SAI and CVC had cleared the appellants, and no new material had emerged to justify reopening the issue.
• The FIR and complaint did not disclose the essential ingredients of cheating or forgery under Sections 420, 468, or 471 IPC. No wrongful gain, dishonest inducement, or use of forged documents was evident.
• The Court emphasized that criminal proceedings must not be used as tools of harassment and cited precedents like Bhajan Lal, Pepsi Foods, and Zandu Pharma in support.
• Therefore, the Court quashed FIR No. 194/2022, related proceedings, and set aside the High Court’s order dated 19.02.2025, terming the case a classic example of abuse of the criminal process.
• Appeals were allowed; no costs were imposed.

Legal Reasoning

• The Court found no prima facie material to establish forgery or cheating.
• The GPF form was neither authenticated nor linked to any wrongful gain.
• There was no use of forged documents proven under Sections 468 or 471 IPC.
• Appellants had already been exonerated by authorities after thorough verification, including medical age tests.
• Reopening settled issues without new material amounted to abuse of process.
• The criminal complaint appeared vindictive, filed years after administrative closure.
• Courts have a duty to prevent misuse of criminal law as reiterated in Bhajan Lal and Pepsi Foods decisions.

Conclusion

The Supreme Court’s judgment reinforces the vital principle that criminal law should not be misused as a weapon of personal vengeance. It affirms the judiciary’s duty to prevent abuse of legal process, especially in cases driven by malice rather than evidence. Recognizing the significant role of sportspersons in national pride, the Court underscored the need to shield individuals of public standing from baseless and vindictive litigation. By quashing the FIR and related proceedings, the Court protected the appellants’ reputations and careers, noting that no prima facie offence was made out. It emphasized that reliance on an unauthenticated document, unsupported by fresh evidence or prior civil challenges, could not justify criminal prosecution. This verdict sets an important precedent for the early quashing of proceedings where allegations are speculative and investigations have previously been closed. It reaffirms judicial intervention as essential when continuing the process would only cause undue hardship and injustice.

Reference(S):

[1] Zandu Pharmaceutical Works Ltd. v. Mohd. Sharaful Haque, AIR 2005 SC 9 (2004).

[2] State of Haryana v. Bhajan Lal, AIR 1992 SC 604.

[3] Pepsi Foods Ltd. v. Special Judicial Magistrate, (1998) 5 S.C.C. 749 (India).