FIR Quashed in Age Fraud Case Against Lakshya and Chirag Sen

On July 28, 2025, the Supreme Court quashed an FIR against badminton players Lakshya Sen and Chirag Sen, their parents, and coach U. Vimal Kumar, in connection with the alleged falsification of the Sen brothers’ birth records.[1] It held that the case warranted interference at the threshold to prevent abuse of the criminal process.

Background

The proceedings stemmed from a complaint lodged by one Nagaraja M.G. (Respondent No.2 herein), in June 2022, alleging that the Sen brothers had misrepresented their dates of birth to qualify for tournaments in the Under-13 and Under-15 categories and thereby gained wrongful selection and monetary rewards. It was further alleged that their parents and coach had conspired to forge and fabricate records in support of the misrepresentation.

Since no FIR was registered on the basis of this complaint, Nagaraja filed a private complaint with the Magistrate, which came to be registered as P.C.R. No. 14448/2022. On verification of the documents produced by the complainant, the Magistrate referred the matter for investigation. Accordingly, an FIR came to be registered invoking provisions of the Indian Penal Code, 1860, against the appellants.

Though the investigation was undertaken, proceedings were stayed by the Karnataka High Court upon writ petitions filed by the appellants. However, the High Court, vide order dated February 19, 2025, declined to quash the criminal proceedings.

Aggrieved by the above, the appellants approached the Supreme Court, which ordered a stay on further proceedings in connection with the FIR on February 25, 2025.

Supreme Court’s Observations

The Supreme Court made the following key observations while quashing the FIR:

• Reliance on GPF Form: The Court expressed that the entire edifice of the complaint was built upon a solitary document, the 1996 GPF nomination form, which not only lacked authentication but also failed to establish any fraudulent intent or act attributable to the appellants. Even assuming the form was genuine, it could not override the birth certificates issued by statutory authorities. Moreover, the complainant did not challenge the validity of the official birth records before any civil forum nor explain why the alleged discrepancies were not raised contemporaneously.

• Prior Verifications by Competent Authorities: The Court noted that the issue of age discrepancy had already been examined at the administrative level. In 2016, the Sports Authority of India (SAI) had initiated a verification process after receiving complaints, and accordingly, the players underwent bone ossification and dental examination tests. The findings of these tests supported the birth years as recorded in official documents, and SAI closed the case. The Central Vigilance Commission (CVC) was also seized of the issue and recommended no disciplinary proceedings against D.K. Sen.

It was emphasised that while the conclusion of administrative bodies was not conclusive for criminal liability, they were relevant in assessing whether a complaint disclosed prima facie grounds to proceed further. And the Court pointed out that there was no new evidence to justify reopening what had already been closed upon due enquiry.

• Essential Ingredients of IPC Provisions Not Fulfilled: The complaint failed to disclose the basic elements required to attract offences punishable under Sections 420 (cheating and dishonestly inducing delivery of property), 468 (forgery for purpose of cheating), and 471 (using as genuine a forged document or electronic record) of the IPC. Also, during the hearing, no satisfactory explanation was provided to clarify the nature of involvement of the players, their parent, or the coach in any act amounting to forgery or cheating.

• Abuse of Process: Based on the material placed on record, it was gathered that the allegations were based on conjecture and surmises, and were manifestly intended to malign the appellants. No dishonest inducement/gain or wrongful loss was demonstrated. The timing of the complaint raised concerns, especially since Nagaraja’s daughter was denied admission to the Prakash Padukone Badminton Academy in 2020. The delay, lack of fresh material, and apparent personal grudge undermined the bona fides of the complaint.

Moreover, the Court observed that compelling Lakshya and Chirag, players with unblemished records who have brought distinction to the country, 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, the Court stated, would amount to an abuse of process.

Stressing that courts must not remain passive in the face of manifest injustice, the Supreme Court proceeded to set aside the Karnataka High Court’s order and quashed the FIR and all further proceedings in pursuance thereof.

[1] Chirag Sen and Ors. v. State of Karnataka and Anr. (Criminal Appeal Nos. 3213-3215/2025).