Evident Pattern Of Vindictiveness: Supreme Court Quashes Criminal Case Against National-Level Badminton Players Accused Of Falsification Of Birth Records
The appeals before the Supreme Court arose from a common judgment passed by the Karnataka High Court whereby the High Court declined to quash the criminal proceedings initiated against the players.
While taking note of the evident pattern of vindictiveness that permeated the complaint, the Supreme Court has quashed a criminal case against national-level badminton players Chirag Sen and Lakshya Sen. The allegations related to falsification of birth records to secure benefits and selections in age-restricted badminton tournaments.
The appeals before the Apex Court arose from a common judgment passed by the Karnataka High Court whereby the High Court declined to quash the criminal proceedings initiated against the appellants accused.
The Division Bench of Justice Sudhanshu Dhulia and Justice Aravind Kumar stated, “What is of greater concern is the evident pattern of vindictiveness that permeates the complaint. The undisputed timeline indicates that the complainant’s grievances commenced only after his daughter was denied admission to the academy in 2020. The FIR was registered in 2022— after the same matter was examined and closed by multiple authorities, including the CVC, which is a premier integrity institution under the Government of India. The delay, absence of new material, and apparent personal grudge collectively undermine the bona fides of the complaint.”
Factual Background
The first and third appellants are established badminton players of national acclaim. The fourth Appellant is a reputed national coach and director of the Prakash Padukone Badminton Academy (PPBA). The proceedings emanated from a complaint lodged by one of the Respondents alleging that the appellant-players had misrepresented their date of birth to qualify for tournaments in the Under-13 and Under-15 categories and thereby gained wrongful selection and monetary rewards. It was alleged that their parents, along with the coach had conspired to forge and fabricate records in support of the misrepresentation.
An FIR came to be registered under Sections 420, 468, 471, and 34 of the Indian Penal Code, 1860, against the appellants. The appellants instituted three separate writ petitions before the High Court, but the same were dismissed. Aggrieved thereby, the appellants approached the Apex Court.
Reasoning
The Bench was of the view that the present case fell squarely within the category of exceptional circumstances warranting interference at the threshold to prevent abuse of the criminal process. On a perusal of the facts of the case, it was noticed that the entire edifice of the complaint was built upon a solitary document, the 1996 GPF nomination form, which was not only bereft of authentication but also failed to establish any fraudulent intent or act attributable to the appellants. The said form did not override the birth certificates issued by statutory authorities, nor did it constitute proof of any falsification on the part of appellants themselves.
The complainant had 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. “It is evident from the material placed on record that the allegations are based on conjecture and surmises, and are manifestly intended to malign the appellants. No dishonest inducement or gain is demonstrated, nor is there any wrongful loss caused to the State or a third party. The allegations against the appellants do not fulfil the essential ingredients of Sections 420, 468 or 471 IPC”, it said.
Noting that the Sports Authority of India closed the matter and the Central Vigilance Commission, an independent oversight body, recommended no disciplinary proceedings, the Bench stated, “These findings were accepted by the relevant authorities and have not been set aside or reopened. 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.”
The Bench found that the complainant’s grievances commenced only after his daughter was denied admission to the academy in 2020. The FIR was registered in 2022— after the same matter was examined and closed by multiple authorities, including the CVC, which is a premier integrity institution under the Government of India. The delay, absence of new material, and apparent personal grudge collectively undermined the bona fides of the complaint. It was further held that the very allegations sought to be revived were earlier subjected to scrutiny by competent authorities, which found no material to proceed further. No fresh evidence had since come to light that would justify reopening what had already been closed upon due enquiry.
“The appellants, particularly Appellant Nos. 1 and 3, are sportspersons of national standing, having represented India in international badminton tournaments and having earned multiple accolades, including medals at the Commonwealth Games and BWF international events. To compel such individuals who have maintained an unblemished record and brought distinction to the country through sustained excellence,to undergo the ordeal of a criminal trial in the absence of prima facie material would not subserve the ends of justice. The invocation of criminal law in such circumstances would amount to an abuse of process, which this Court cannot countenance”, the order read.
Thus, allowing the appeal, the Bench set aside the order of the High Court and quashed the FIR and further proceedings in question.
Cause Title: Chirag Sen and Another Etc v. State of Karnataka and Another (Neutral Citation: 2025 INSC 903)