Home » News » Supreme Court’s Firm Hand: Slaps Rs 25 Lakhs Penalty on Complainant, Puts an End to Unscrupulous Litigation Tactics

In the recent case of Dinesh Gupta v. The State of Uttar Pradesh & Anr., the Supreme Court demonstrated a resolute stance against the misuse of legal channels. This legal saga involves the respondent’s FIR against company promoters resulting in the Court’s rebuke for false jurisdiction and forum shopping. The Court’s imposition of a ₹25 lakh penalty on the complainant, Karan Gambhir reflects a decisive stand against unscrupulous litigation tactics. This landmark judgment emphasizes the necessity to preserve the integrity of the legal system and deter malicious legal pursuits marking a significant step towards curbing such misconduct.


Dinesh Gupta v. The State of Uttar Pradesh & Anr., 2024 LiveLaw (SC) 33 Supreme Court
Coram: Justices Vikram Nath and Rajesh Bindal


• In this case, the respondent/complainant lodged an FIR against the promoters of three companies accusing them of forgery and cheating.
• He asserted that his company was misled into providing short-term loans to the accused firms.
• The Chief Judicial Magistrate of Gautam Budh Nagar issued the summons following the allegations.
• The accused individuals/appellants contested this decision by approaching the High Court.
• With their plea rejected, they have now filed the current appeal.


Addressing the issue of false jurisdiction, the Supreme Court observed that although the FIR was registered in Noida, the registered offices of the concerned companies were in Delhi. The Court characterized this as “wishful forum shopping” by the complainant raising doubts about their intentions. Regarding the Trial Court’s order that took cognizance and issued summons, the Court criticized it for a lack of application of mind. It pointed out the failure to consider the addresses of the complainant, accused companies and their Directors highlighting a deficiency in the judicial process.
The Court noted that the complainant concealed material facts concocting a new narrative of document forgery to give the complaint a criminal nature. Expressing displeasure, the Court recorded that the respondent opted for criminal charges to misuse the system for personal vendetta rather than seeking true justice.
Describing the conversion of a civil matter into a criminal case as burdensome to the justice system and a violation of fairness principles, the Court stressed the potential damage to trust in the legal system and the harmful precedent set by such actions. Additionally, the Court highlighted that a short-term loan from 2010 remained unaddressed until the FIR filed 8 years and 7 months later. It opined that these details exposed the ulterior motives of the complainant indicating a deliberate and unnecessary delay for initiating baseless litigation.


The Supreme Court on January 11 strongly criticized the litigant for misusing the legal system by filing a false and frivolous complaint without disclosing essential facts. The Court rebuked the respondent for engaging in forum shopping and initiating an FIR against the appellants despite the commercial nature of the dispute.
In response to these actions, the Supreme Court imposed a penalty of ₹25 lakhs on the respondent, Karan Gambhir. This amount is required to be deposited within four weeks with the Registry of the Court. Once received, the sum will be equally distributed to the SCBA & SCAORA for the development and benefit of their members.
The Court, emphasizing the need to curb such misuse of the legal process, stated that unscrupulous litigants should not be allowed to escape consequences. It insisted on imposing strict terms and conditions, including costs, and emphasized the importance of addressing litigation tainted with concealment, falsehood, and forum hunting. The Court also advocated for reprimanding State actions or the conduct of government servants involved in such malicious litigation.

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