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Chirag Sen and Another Etc. v. State of Karnataka

Criminal Appeal · 2025 INSC 903Decided 28 Jul 2025
Crl.A. No.-003213-003215-2025 (arising out of SLP(Crl.) Diary No. 9824 of 2025)
Justice Sudhanshu Dhulia · Justice Aravind Kumar

Background

National-level badminton players Chirag Sen and Lakshya Sen, their parents, and their coach at the Prakash Padukone Badminton Academy were accused by a private complainant of falsifying the players' birth records years earlier to wrongly qualify them for age-restricted junior tournaments. The same allegations had already been examined around 2016-2018 by the Sports Authority of India, medical boards (including bone-age tests at AIIMS), and the Central Vigilance Commission, all of which found the birth records genuine and closed the matter. Nearly eight years later, after the complainant's daughter was denied academy admission, he filed a private complaint that led to an FIR under IPC cheating and forgery provisions; the Karnataka High Court declined to quash it, so the accused appealed to the Supreme Court.

Decision Breakdown

The Supreme Court allowed the appeals and quashed the FIR and all related proceedings. It held that the complaint rested on a single, unauthenticated 1996 document that did not even establish any act of forgery or dishonest inducement by the accused, and that the essential ingredients of cheating and forgery under Sections 420, 468 and 471 IPC were not made out even on the complainant's own case. The Court found a clear pattern of delay and personal vindictiveness, the complaint surfaced only after an unrelated admission dispute, and that reopening issues already settled by specialized bodies like SAI and the CVC, without any new evidence, amounted to abuse of the criminal process that courts have a duty to interdict.

Lesson Learnt

Criminal courts will step in to quash an FIR at the threshold where a complaint is built on stale, unsubstantiated allegations already examined and closed by competent authorities, especially where the timing and circumstances suggest the criminal process is being used to settle personal scores rather than to prosecute a genuine offence.

Official source (sci.gov.in)View Judgment (PDF)

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