Summary and Analysis of Chirag Sen and Anr. Etc. vs. State of Karnataka

1. Heading of the Judgment

Case Title: Chirag Sen and Another Etc. vs. State of Karnataka and Another
Court: Supreme Court of India
Jurisdiction: Criminal Appellate Jurisdiction
Judgment Date: July 28, 2025
Judges: Justice Sudhanshu Dhulia and Justice Aravind Kumar
Citation: 2025 INSC 903

2. Related Laws and Sections

The judgment primarily deals with the following legal provisions:

• Sections 420, 468, 471, and 34 of the Indian Penal Code (IPC), 1860: Pertaining to cheating, forgery, using forged documents as genuine, and criminal conspiracy.

• Section 156(3) of the Criminal Procedure Code (CrPC): Empowering magistrates to direct police investigation.

• Articles 226 and 227 of the Constitution of India: Conferring writ jurisdiction on High Courts.

• Section 482 CrPC: Inherent powers of the High Court to quash criminal proceedings to prevent abuse of process.

3. Basic Judgment Details

• Appellants:
  Chirag Sen and Lakshya Sen (national-level badminton players).
  Their parents (Nirmala Dhirendra Sen and Dhirendra Kumar Sen).
  U. Vimal Kumar (national badminton coach).

• Respondents:
  State of Karnataka.
  Nagaraja M.G. (complainant).

• Allegations:
  Falsification of birth records to gain eligibility in age-restricted badminton tournaments.
  Fabrication of documents for wrongful benefits.

• Lower Court Proceedings:
  A private complaint led to an FIR (No. 194/2022) under Sections 420, 468, 471, and 34 IPC.
  The Karnataka High Court declined to quash the FIR, prompting the appeal to the Supreme Court.

4. Explanation of the Judgment

Background of the Case

The case arose from a complaint alleging that the appellants, particularly Chirag Sen and Lakshya Sen, misrepresented their ages to participate in junior badminton tournaments. The complaint accused their parents and coach of conspiring to forge birth records. Despite prior investigations by the Sports Authority of India (SAI) and the Central Vigilance Commission (CVC), which found no wrongdoing, a fresh FIR was registered in 2022 based on an unverified GPF nomination form from 1996.

Key Contentions

• Appellants' Arguments:
  The allegations were baseless, motivated by personal vendetta (the complainant’s daughter was denied academy admission in 2020).
  Official birth certificates and medical age verification reports (including AIIMS tests) supported their documented ages.
  The GPF form was unauthenticated and irrelevant to the players’ birth records.

• Respondent's Arguments:
  The GPF form indicated discrepancies in birth records.
  Criminal investigation was necessary to uncover the truth, regardless of prior administrative closures.

Supreme Court’s Findings

1. Lack of Prima Facie Evidence:
   The FIR relied solely on the 1996 GPF form, which was neither authenticated nor linked to any fraudulent act by the appellants.
   No evidence showed the players or their coach forged documents or gained wrongful benefits.

2. Abuse of Process:
   The complaint was filed after an 8-year delay, with no new material. The Court noted it was likely driven by malice, not justice.
   Prior inquiries by SAI and CVC had already cleared the appellants, making the FIR redundant.

3. Legal Principles Applied:
   Citing Zandu Pharmaceutical Works Ltd. v. Mohd. Sharaful Haque and State of Haryana v. Bhajan Lal, the Court emphasized that proceedings without merit must be quashed to prevent harassment.
   The absence of essential ingredients for offences under Sections 420, 468, and 471 IPC rendered the FIR unsustainable.

4. Protection of Reputation:
   The appellants, being accomplished athletes, had unblemished careers. Allowing a trial without evidence would harm their reputations unjustly.

Final Decision

The Supreme Court quashed the FIR and all related proceedings, ruling that:

• The allegations were speculative and lacked criminal intent.

• Continuation of proceedings amounted to an abuse of the legal process.

• The High Court erred in not exercising its jurisdiction under Section 482 CrPC to prevent injustice.

Conclusion

The judgment underscores the judiciary’s role in safeguarding individuals from frivolous litigation while upholding the sanctity of verified official records. It reaffirms that criminal law cannot be weaponized for personal grievances, especially when competent authorities have already adjudicated the matter. The ruling protects the appellants’ dignity and careers, setting a precedent against vexatious prosecutions.