In a landmark decision rendered by the Supreme Court of India in the case of Chirag Sen and another Vs. state of Karnataka and another dated July 28, 2025, criminal cases against two badminton players who had achieved national prominence Chirag Sen and Lakshya Sen and their family members and the coach were also quashed. The issue was about age fraud and forgery of birth certificate. The order, given by the bench comprising of Justice Aravind Kumar, J., and Sudhanshu Dhulia, J., is informative on how the court has intervened to deal with the mis-utilization of the provisions of criminal law in carrying on personal vendetta, as well as subjecting people to the unnecessary harassment as not required by the provisions of criminal Law.
Background of the Case
The appeals were against a common judgment of the High Court of Karnataka, the High Court of Karnataka at Bengaluru dated February 19, 2025. The High Court had denied the full criminal proceedings against the appellant, which were brought against the appellants on allegation that they had backdated their birth records to participate in badminton tournaments with age-restriction. The appellants comprised badminton players Chirag Sen (26) and Lakshya Sen (23) their parents Nirmala Dhirendra Sen (57) and Dhirendra Kumar Sen (62) and their coach, U. Vimal Kumar (63).
The case arose in circumstances through a complaint made on June 27, 2022 by Respondent No. 2 Shri Nagaraja M.G. The complaint says that the Two brothers, Chirag Sen and Lakshya Sen have falsely presented their date of birth certificates to be selected to Under-13 and Under-15 tournaments and has received wrongful selection and financial gains. There was also the claim that there was a conspiracy among their parents and coach in order to forge and fabricate documents to facilitate this misrepresentation. In the absence of FIR the private complaint under Section 200 of the Criminal Procedure Code was filed by the complainant. Later on, the case was registered on December 1, 2022, under Section 420 (cheating), 468 (forgery with intent to commit cheating), 471 (using forged document as genuine), and 34 (act in furtherance of common intention) of the Indian Penal Code.
Administrative Investigations and Pre-termination
What was critical about the argument that the appellants were making was that these claims were not novel. Likewise allegations had been leveled sometime 9 years ago and examined by sufficient authorities, variously Sports Authority of India (SAI), Central vigilance Commission (CVC) and Education Department, Government of Karnataka. The players were subjected to medical checkup especially on bone ossification and dental checkup in government hospitals such as AIIMS, Delhi. These tests confirmed the year of their birth that was indicated in the official documents. Due to this, SAI had closed the case. The CVC too had also looked into the case and in an Official Memorandum that is dated February 6, 2018, said that the birth certificate and 10th-grade certificate indicating are final. Although the complainant did not stop at this administrative closure, but went on to initiate again new criminal proceedings nearly eight years later.
The Complaint is based on Shaky Documentation
Turning to the second argument raised by the appellants, the whole case of the prosecution against the appellants was established by a single document namely the 1996 unverified and unauthenticated GPF (General Provident Fund) nomination document. The complainant was claiming this form indicated various birth dates undertaken by the players and that the same were later modified. The counsel of the appellants Mr. C.A. Sundaram claimed that this form was inadmissible in the sense that this form was neither authenticated nor put through any forensic tests. Moreover, he highlighted that as Lakshya Sen was born after 1996, he could never be referred to in a 1996 nomination form. In its investigation, the Supreme Court identified that the GPF form, whether genuine or otherwise, could not be a substitute of other statutory documents such as birth certificates nor did it reflect any malafides. The court observed that there was no challenge by the complainant in any civil court to the validity of the official birth records.
Unlawful means and malice in Act
The Supreme Court was more poignant in the evident pattern of vindictiveness which was behind the complaint. The chronology of events pointed to the fact that it was not until that time in 2020 when his daughter was turned away by the Prakash Padukone Badminton Academy that the complainant developed grievances. The FIR has been registered in 2022, and the same concerns were already discussed extensively and concluded by various authorities, one of which was the CVC. The court noted that delay, the lack of any new development and the personal repugnance that appeared formed a consortium that compromised the bona fides of the complaint. The ruling referred to the precedent of
State of Haryana v. Bhajan Lal that laid down the fact that courts are bound to interfere where criminal proceeding is brought upon with an ulterior motive of taking a vengeance.
Section 184 and Section 465 of IPC- Lawful and Unlawful Examination Legally Analyzing and Inapplicability of IPC Sections
The Supreme Court did a thorough examination of the charges that had been brought out against the appellants. It had ruled that the charges did not meet the ingredients required under Sections 420, 468 and 471 of the Indian Penal Code. The court detected no instance of the appellants having created or signed a document, an instance where the appellants knowingly used a forged document, or even created a forged document as real. Besides, the commission of such an act was not alleged to have caused or induced anyone to voluntarily relinquish property or confer a benefit upon someone dishonestly. The court highlighted that the complaint was not able to show how the players or their coach (minors when the alleged GPF form was prepared) had any part in the preparation or use of the said form. The fact that there was no direct or indirect material tying the appellants to an act of culpability served to strengthen the contentions of the court that the accusation did not pass the threshold required to take the case to a criminal induction level. Another principle reconfirmed by the court is
Pepsi Foods Ltd. v. Special Judicial Magistrate in which they held as follows, that summoning of an accused in a criminal proceeding can never be considered lightly.
The Supreme Court in its final judgement stated that the extended criminal proceedings was, in totality, unjustified. The court pointed out that the allegations that were reuvenated were ones that had previously been investigated by proper bodies and they had been closed by proper bodies and that there was no new evidence that reviving the matter would be based on. It identified the appellants specially Chirag sen and Lakshya sen as national level sportsperson whose achievements had made the country proud. It will be an abuse of process to make them go through a criminal trial without having prima facie material. The Apex court entertained the appeals, struck down the order passed by the High Court and quashed the F. I R and all proceedings thereof, thus sending a clear message regarding personal vendetta entered with the help of legal machinery.
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