Supreme Court quashes FIR over alleged age-fraud of national badminton players, finds criminal process abused

A Bench of Justices Sudhanshu Dhulia and Aravind Kumar heard appeals against a Karnataka High Court order which had declined to quash criminal proceedings arising from allegations of falsification of birth records to secure eligibility in age‑restricted badminton tournaments.

The Court allowed the appeals, set aside the High Court judgment dated 19.02.2025 and quashed FIR No. 194/2022 registered at High Grounds Police Station, Bengaluru, together with all consequential proceedings including P.C.R. No. 14448/2022. The bench held that the complaint rested on “a solitary document” that was unauthenticated and that the allegations did not disclose the essential ingredients of the offences charged under Sections 420, 468 and 471 IPC. The Court, in its reasoning, observed: "The entire edifice of the complaint is built upon a solitary document, the 1996 GPF nomination form—which is not only bereft of authentication, but also fails to establish any fraudulent intent or act attributable to the appellants. The said form, even if assumed to be genuine, does not override the birth certificates issued by statutory authorities, nor does it constitute proof of any falsification on the part of appellant Nos.1 and 3 themselves. The complainant has 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. In Zandu Pharmaceutical Works Ltd. v. Mohd. Sharaful Haque, (2005) 1 SCC 122, this Court reiterated that where allegations are inherently improbable and no case is made out, continuation of proceedings amounts to abuse of process." The Court further noted that "the continuation of the criminal proceedings against the appellants is wholly unwarranted."

Background The dispute originated from a private complaint dated 27.06.2022 by Shri Nagaraja M.G., alleging that Chirag Sen and Lakshya Sen misrepresented their dates of birth to qualify for Under‑13 and Under‑15 badminton tournaments and that their parents and coach conspired to forge records. No FIR had been registered initially; the complainant filed a private complaint under Section 200 Cr.P.C. and the Magistrate directed investigation under Section 156(3) Cr.P.C., leading to FIR No. 194/2022 dated 01.12.2022 invoking Sections 420, 468, 471 and 34 IPC.

The appellants — two nationally acclaimed sportspersons, their parents and a coach associated with the Prakash Padukone Badminton Academy — challenged the registration of the FIR by filing writ petitions under Articles 226 and 227 and Section 482 Cr.P.C. before the Karnataka High Court. The appellants relied on earlier institutional inquiries: the Sports Authority of India, Central Vigilance Commission and other authorities had examined age‑fraud allegations years earlier; the CVC, by memorandum dated 06.02.2018, had observed that the birth certificate and Class X certificate were final and SAI had closed its inquiry. The appellants contended that the present complaint was mala fide, premised on an unauthenticated 1996 GPF nomination form, and that medical assessments supported the recorded birth years.

The High Court declined to quash the proceedings, observing that documents produced prima facie warranted investigation. On appeal to this Court, the Supreme Court carefully examined the material, including prior administrative findings, the delay in lodging the complaint and the absence of any new material or explanation for the long gap. The Court held that institutional closure by specialised agencies bore relevance to whether a prima facie case existed and found no satisfactory linkage between the appellants and any act of forgery or dishonest inducement. Applying established precedents on abuse of process, the Court concluded that reopening settled administrative inquiries without fresh evidence and compelling sportspersons of national standing to undergo criminal trial would not serve the ends of justice. Consequentially, the FIR and pending proceedings were quashed and the appeals were allowed; pending applications were disposed of and there was no order as to costs.

Case No.: 2025 INSC 903 Case Title: Chirag Sen and Another v. State of Karnataka and Another Appearances: For the Petitioner(s): Mr. C.A. Sundaram, Senior Counsel For the Respondent(s): (Counsel not specified in the judgment)