Inquiry Into Forged Judicial Orders Must Precede Consideration of Recall Application: Bombay HC Directs Registrar General to Lodge Complaint

The Court held that the issue of how and at whose instance the forged judicial orders came into existence must first be investigated, and directed the Registrar General to lodge a police and cyber cell complaint, deferring consideration of the recall application until completion of the inquiry.

forged judicial orders

Bombay High Court: In a matter concerning recall of earlier orders on the ground that forged judicial orders had been circulated, a Single Judge Bench of Arif S. Doctor, J., observed that before proceeding further, the issue of how and at whose instance such forged/fabricated orders came into existence is crucial and must be investigated. The Court directed the Registrar General to lodge an appropriate complaint with the competent police authorities and the cyber cell, and to place a report within 4 weeks. The Court clarified that the interim application shall be taken up for consideration only after completion of the inquiry.

Also Read: Supreme Court issues bailable warrants against Advocate to account for FIR in 1971 Forgery Case; Stays arrest of 71-year-old woman

Background

The applicant filed an interim application seeking recall of the orders dated 24 January 2025 and 7 February 2025. It was contended that the additional respondent, engaged as advocate, had forged/fabricated the orders annexed and sent them to the applicant instead of the genuine orders annexed.

The additional respondent appeared in person and denied the allegations, asserting that the fabrication was at the hands of the applicant. However, the applicant denied this and submitted that he was willing to face any inquiry into the allegations.

Analysis and Decision

The Court emphasised that before proceeding further in the matter, the issue of how and at whose instance the orders annexed have come into existence is crucial and must be investigated into.

Accordingly, the Court directed the Registrar General to lodge an appropriate complaint with the competent police authorities as well as the cyber cell, and to take all necessary steps for conducting an inquiry into the circumstances in which the forged/fabricated orders came into existence. The Court ordered that a report be placed before it within 4 weeks.

The Court clarified that it had not considered the merits of any allegations made by the parties in the interim application. It was further noted that the interim application shall be taken up for consideration only after completion of the inquiry.

Also Read: Will offence of forgery, fabrication, and filing of false affidavit, warrant lodging of complaint u/S. 340 CrPC? Delhi HC explains

[Shylender Jindal v. Purvi Shah, Interim Application No. 2829 of 2025, decided on 18-6-2026]


Advocates who appeared in this case:

For the Applicant: Ryan D’souza and Shivam Laturiya & Sujit Bhuyare i/b Mr. Shivam Laturiya, Mr. Vikramaditya Deshmukh a/w Ms Priya Chaubey i/b Ms Sapna Rachure

For the Additional Respondent: Purvi Shah

Dor Defendant No. 6: Mr. Hitendra Parab a/w Mr. Sanket Lohote i/b Mr. Harsh Parte

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