Background of the Case
The Karnataka High Court has dismissed a criminal petition filed by former Union Minister Maneka Sanjay Gandhi seeking to quash criminal defamation proceedings initiated against her by S.K. Mittal.
The private complaint alleges offences punishable under Sections 499 and 500 of the Indian Penal Code, 1860, relating to criminal defamation.
The complaint was initially dismissed by the trial court on November 16, 2019. Aggrieved by the dismissal, the complainant approached the jurisdictional Sessions Court by filing Criminal Revision Petition No. 125/2025.
On June 30, 2025, the Sessions Court allowed the revision petition, set aside the trial court's dismissal order and remitted the matter for fresh consideration.
Upon reconsideration, the trial court took cognizance of the complaint and issued summons to Maneka Gandhi.
Aggrieved by the subsequent proceedings, she approached the Karnataka High Court seeking to quash the criminal proceedings and the orders passed by the trial court.
Arguments on Behalf of Maneka Gandhi
Senior Advocate Sidharth Luthra, appearing for Maneka Gandhi, contended that the trial court had not properly appreciated the material available on record before taking cognizance and issuing summons.
It was argued that the trial court had been influenced by the observations made by the Sessions Court in its earlier revision order dated June 30, 2025, despite the direction to reconsider the matter independently.
Her counsel further submitted that approaching the same Sessions Court again by filing a revision petition would be an ineffective remedy, as that court had already expressed its views while setting aside the earlier dismissal of the complaint.
On these grounds, it was contended that invoking the jurisdiction of the High Court was justified.
Karnataka High Court's Observations
Justice Anant Ramanath Hegde observed that the apprehension expressed by Maneka Gandhi regarding the impartial consideration of her case by the Sessions Court could be addressed by specifically directing that court to independently examine the matter.
The High Court clarified that if she approached the jurisdictional Sessions Court by filing a revision petition, it would be required to consider all aspects of the matter and pass appropriate orders in accordance with law.
The Court emphasised that the Sessions Court must independently assess the trial court's order based on the contents of the complaint, statements recorded and documents placed before the trial court.
Sessions Court Directed to Independently Examine the Matter
The High Court specifically directed the Sessions Court not to be influenced by its earlier order dated June 30, 2025.
The Court observed:
"Jurisdictional Sessions Court in the event of Revision Petition being filed by the petitioner/accused, shall take all aspects into consideration and pass appropriate orders in accordance with law. It is made clear the Court has to independently assess the merit of the order based on the contents of the complaint and the statements recorded and the documents if any, placed before the Trial Court."
The Court further stated:
"The jurisdictional Sessions Court shall not be influenced by the order dated 30.06.2025."
These directions were intended to ensure that any revision petition filed by Maneka Gandhi would receive independent consideration on its merits, notwithstanding the Sessions Court's earlier decision.
High Court Dismisses Petition but Grants Two-Week Protection
After making the above observations, the Karnataka High Court dismissed the criminal petition, leaving Maneka Gandhi at liberty to challenge the trial court's order before the jurisdictional Sessions Court.
The Court also directed that the period spent pursuing the proceedings before the High Court, from October 12, 2026, until October 27, 2026, be excluded while calculating the limitation period for filing a criminal revision petition.
Subsequently, Senior Advocate Sidharth Luthra submitted that Maneka Gandhi had been directed to appear before the trial court on November 7, 2026, and that she was a senior citizen residing in Delhi. He sought protection against further proceedings to enable her to approach the Sessions Court.
Considering her age and residence in Delhi, the High Court stayed the operation of the impugned order for a period of two weeks from October 27, 2026.
The Court expressly clarified that it had not expressed any opinion on the merits of the contentions raised by either party and that all contentions remained open for consideration.
Case Details
Case Name: Maneka Sanjay Gandhi v. S.K. Mittal
Court: High Court of Karnataka, Bengaluru
Date of Decision: October 27, 2026
Case Number: Criminal Petition No. 15792 of 2026
Coram/Judge: Justice Anant Ramanath Hegde
