Supreme Court Grants Regular Bail To Vikram Bhatt And His Wife In Fraud Case; Refers Parties To Mediation

The Supreme Court has granted regular bail to filmmaker Vikram Bhatt and his wife, Shwetambari Bhatt, following their appeal against a Rajasthan High Court order that previously denied them relief. The Court has also referred the parties to the Supreme Court Mediation Centre.

The case stems from an FIR registered at Bhupalpura Police Station in Udaipur, where the complainant, Dr Ajay Murdia, alleged that the couple orchestrated approx. ₹30 crore fraud related to a four-film production agreement involving Indira Entertainment LLP.

Previously, the Court had granted interim bail to his wife.

The Bench of Chief Justice Surya Kant, Justice Joymalya Bagchi and Justice Vipul M Pancholi ordered, "It seems to us that the dispute essentially pertains to a commercial transaction. Though the ingredients of committing offence for cheating etc. have been expressly mentioned in the FIR. Be that as it may, one of the appropriate recourse for the parties would be to make an endeavour to resolve the dispute adequately under the aegis of mediation...Since the Appellants are willing to join and cooperate with the ongoing investigation, we allow this appeal, set aside to the interim order of the High Court, and without expressing any opinion on the merits, direct that Appellant No. 2 be also released. Both the appellants are granted regular bail."

Senior Advocate Siddharth Dave appeared for the Petitioners, while Senior Advocate Viaks Singh appeared for the Respondents.

"The regular bail has been, however, granted with the expectation that the Appellants will act bona fidely and and try and and will make efforts for amicable resolution of the commercial dispute", the Court further added.

Dave submitted, "Though the complainant himself has written to the first petitioner who was released on bail on the day, saying that since you are released on bail, it's time to finish our remaining commitment."

Singh said, "Actually, I'll tell you... His company is in trouble. There is another FIR against him in Bombay doing exactly the same...After my FIR in Bombay, where he's done exactly the same thing. His company is in difficulty. He's actually asking for money because of his reputation, whatever his past reputation is...People are giving him money. And he is using that money for his own lot, for the company which is going into liquidation and taking off those days." 

Dave responded, "My friend's client wants the commitments to go through, writes an email the next day, please do it...Nobody comes on the next day of release. Please, fine, do this, complete the movies, etc. Four movies is the contract. Two are completed. Third is 70% complete. We are saying we'll complete it...By being in custody, I cannot complete any movie of my Learned Friend."

The court viewed the matter primarily as a commercial dispute, despite the presence of criminal allegations like cheating. Since the appellants expressed a willingness to cooperate with the ongoing probe, the High Court’s previous order denying relief was set aside. Bail was granted with the expectation that the parties would act in good faith to resolve their financial disagreements amicably.

Senior Advocate Dave informed the court that the "majesty of the court" had been questioned in the Rajasthan Assembly, where discussions were reportedly held regarding how the court granted interim bail in this matter.

"And after your Lordship passed this order of interim bail, assembly, one person got up in the assembly, questioned how your Lordship could have granted interim bail. Is this the procedure? Because that person is related to the Complainant. In the Rajasthan Assembly, a question was raised that how could your Lordship grant interim bail in this matter. It's very surprising. We have the video, we have the assembly proceeding", Dave submitted.

In this regard, CJI Kant said, "We know then how to take strong action. Only because you belong to Rajasthan and you have some influence there..If any of your machinery misadventures speak anything, we will transfer in a minute everything to Bombay...You can't take any benefit because you are a complainant. You are a pure person in Rajasthan. We would like to understand the warning. Nobody should be under this mistaken belief that because you can speak in assembly, therefore you are guilty. The law will take its own course. If anybody tries to misbehave with the court."

Background

Two bail applications under Section 483 of the B.N.S.S. (Bharatiya Nagarik Suraksha Sanhita) were filed on behalf of the Petitioners herein before the High Court against the orders passed by the Lower Court, seeking regular bail in connection with First Information Report (FIR) No. 213/2025, Police Station Bhupalpura, District Udaipur, for offences under Sections 316(2), 318(4), 336(3), 338, 340(2), and 61(2) of the Bharatiya Nyaya Sanhita (BNS). 

It was the case of complainant Dr Ajay Murdia that, through Dinesh Kataria, a resident of Udaipur, an agreement was made with Mumbai film producer Vikram Bhatt for the production of four films for 47 crore rupees.

Subsequently, Indira Entertainment LLP was formed, and the complainant was made to pay over 42.70 crore rupees in various stages in the name of vendors. However, in reality, only one film was released, the second was left incomplete, the third was only about 25% completed, and shooting for the fourth has not even started to date.

Despite this, it was alleged that Vikram Bhatt and Shwetambari Bhatt pressured the complainant, demanding 8.91 crore rupees and, later, approximately another 11 crore rupees. When the money was not received, shooting was stopped, and they explicitly refused to return all assets related to the films, such as raw footage, hard disks, music master files, costumes, scripts, and IPR. Additionally, pressure was exerted on the complainant through the Federation by creating fake vendor claims worth 2.46 crore rupees. 

Before the High Court, Senior Advocate VR Bajwa and Advocate Manvendra S Bhati, on behalf of Vikram P. Bhatt and Shwetambari V. Bhatt, submitted that they were falsely implicated and had been in custody since December 7, 2025. It was submitted that two films have been prepared, and the work on the remaining two is incomplete, which was stopped based on the complainant's instructions. It was added that the entire scam was committed by the complainant's accountant, Rakesh Panigrahi, for which FIR No. 803/2025 has been registered by the applicants at Versova Police Station, Mumbai. To escape this, the complainant colluded to file this false case.

The High Court, considering the nature of the evidence, the factual situation, and other circumstances, and without expressing any final opinion on the merits of the case, refused to grant bail to the Petitioners herein.

Cause Title: Shwetambari Bhatt and Anr. v. State of Rajasthan [SLP(Crl) 2647/2026]