It is entirely in the fitness of things and so also absolutely in order that the Madhya Pradesh High Court at Jabalpur, in a most learned, laudable, landmark, logical and latest judgement titled 'Rahul Gandhi Vs Kartikey Singh Chauhan' in Misc. Criminal Case No. 13941 of 2026 and cited in Neutral Citation No.: 2026:MPHC-JBP:44938 and also in 2026 LiveLaw (MP) 235 that was pronounced most recently on 25.06.2026, closed a defamation case that had been lodged by Kartikey Singh Chauhan, who is the son of former Chief Minister of Madhya Pradesh and now Union Agriculture Minister Shivraj Singh, against Congress leader Rahul Gandhi, alleging that the latter made false and defamatory statements against Kartikey during an election rally in 2018.
It must be noted that a single judge bench comprising the Honourable Mr Justice Pramod Kumar Agrawal delivered its pragmatic judgement on a petition that had been submitted by Rahul Gandhi, who is the Leader of the Opposition in the Lok Sabha and who had sought relief from the court in a defamation case that had been lodged against him by Kartikey in an MP/MLA court in Bhopal. Shivraj Singh was the Chief Minister of Madhya Pradesh when the statement was made in 2018.
Rahul Gandhi's Regret Statement Before Madhya Pradesh High Court
It merits noting that on June 24, 2026, Rahul Gandhi had filed a written statement before the Madhya Pradesh High Court expressing his deep regret over the egregious statement that he had made during an Assembly election rally in the Jhabua district in October 2018 and clarified that he had “erroneously” named Kartikey while making a reference to the Panama Papers.
It must be recalled that Kartikey had approached an MP/MLA court in Bhopal which had, in December 2024, issued summons to Mr Gandhi for personal appearance. The Jabalpur High Court noted that Kartikey had accepted Rahul Gandhi’s regret and he did not want to escalate the matter further. So it is entirely in order that the Madhya Pradesh High Court at Jabalpur very rightly closes the defamation case that had been lodged against Rahul Gandhi.
Key Highlights of the Case
- Case Title: Rahul Gandhi Vs Kartikey Singh Chauhan
- Court: Madhya Pradesh High Court, Jabalpur Bench
- Case Number: Mis c. Criminal Case No. 13941 of 2026
- Neutral Citation: 2026:MPHC-JBP:44938
- LiveLaw Citation: 2026 LiveLaw (MP) 235
- Date of Judgment: 25.06.2026
- Presiding Judge: Hon’ble Mr Justice Pramod Kumar Agrawal
- Issue: Defamation proceedings against Rahul Gandhi
- Outcome: Proceedings closed after Rahul Gandhi expressed regret and Kartikey Singh Chauhan accepted the same.
Interlocutory Application Under Section 528 BNSS
By the way, Rahul Gandhi had filed an interlocutory application before the Jabalpur High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, stating that reference to Kartikey Singh had been made inadvertently.
Rahul Gandhi had clarified, submitting that he had publicly clarified on October 30, 2018, that he intended to refer to the son of the Chhattisgarh Chief Minister – Raman Singh at the time – and not Madhya Pradesh in connection with the media reports surrounding the Panama Papers disclosure. Abhishek Singh, who is the son of Raman Singh, had denied the allegations made by Rahul Gandhi.
It is glad to see that Congress MP and eminent and senior Supreme Court lawyer Vivek Tankha, who appeared in the Jabalpur High Court as Rahul Gandhi’s lawyer, minced absolutely just no words to say that "publicly acknowledging a mistake ‘is the hallmark of a true and honest person’.” No denying or disputing it!
Observations of the Madhya Pradesh High Court
At the very outset, this pragmatic, persuasive, praiseworthy and pertinent judgment authored by a Single Judge Bench comprising the Hon’ble Mr Justice Pramod Kumar Agrawal of Madhya Pradesh High Court at Jabalpur sets the ball in motion by first and foremost putting forth in para. 1 that,
“Applicant has preferred the present petition filed u/s 528 of BNSS challenging the order dated 13.12.2024 passed by the learned Trial Court taking cognizance of the offence punishable under Section 500 of the Indian Penal Code, 1860, in Criminal Case No. S.C.P.P.M. 3/2025 and summoning the applicant.”
Background and Core Issue Before the Court
To put things in perspective, the Bench envisages in para 2 while elaborating on the core issue stating concisely that,
“During pendency of the petition, applicant has moved I.A. No.14821/2026, which is an application for bringing on record the applicant’s statement of which paragraphs 2 and 3 are reproduced as under:-
2. That the applicant on October 29th, 2018, during the then ongoing Assembly Election campaign, made the allegedly defamatory statement in Jhabua, wherein a reference was made to so-called Panama Papers. Upon discovering that Respondent’s name erroneously appeared in the said statement, on the very next day — i.e. on October 30th, 2018 — the applicant clarified in public that who he had intended to refer to was the son of the former Chief Minister of Chhattisgarh as having been named in the widely reported Panama Papers controversy and not the Respondent or his father, the then Chief Minister of Madhya Pradesh. The applicant, thus, express his regret express his regret. The applicant stands by the said public clarification and look forward to voluntary cessation of proceedings.
3. That, in view of the above, it would be in the interest of justice if the case is closed and proceedings before the learned Trial Court are dropped against the applicant.
Quick Reference Table
| Particular | Details |
|---|---|
| Petitioner | Rahul Gandhi |
| Respondent | Kartikey Singh Chauhan |
| Court | Madhya Pradesh High Court, Jabalpur |
| Judge | Hon’ble Mr Justice Pramod Kumar Agrawal |
| Provision Invoked | Section 528, Bharatiya Nagarik Suraksha Sanhita, 2023 |
| Original Offence | Section 500, Indian Penal Code, 1860 (Defamation) |
| Result | Defamation proceedings closed |
Court Observations on Written Reply and Expression of Regret
It is worth noting that the bench notes in para 3 that, “On behalf of the respondent, a written reply has been filed in which it is mentioned that in view of subsequent developments, the regret expressed by the applicant and the statement brought on record, the answering respondent/complainant does not intend to escalate the issue further, and the proceedings before this court as well as the trial court be closed after making the verbatim statement brought on record vide I.A. No. 14821/2026 part of the final order whereby regret has been expressed for making the alleged defamatory statement.”
Senior Counsel's Submissions
It is also worth taking into account that the bench points out in para. 4 that, “Learned senior counsel for the applicant submits that the applicant has expressed his regret, which has been accepted on behalf of the respondent in a written reply, and the respondent is also agreed if the proceedings be closed before this court as well as the trial court."
Respondent's Stand Before the Court
As things stand, the Bench observes in para 5 that, “Learned counsel for the respondent submits that in this case vide I.A. No. 14821/2026 the applicant has clarified and expressed regret, which is mentioned in paragraphs 2 and 3; therefore, in the light of such a statement and expressing his regret, the further proceedings before this Court as well as the trial court be closed/disposed of."
Court Hears Both Sides
Needless to say, the Bench states in para 6 that, “I have heard learned Senior Counsel for the applicant and counsel on behalf of respondent/complainant.”
Petition Under Section 528 of BNSS
Quite significantly, it would be instructive to note that the Bench hastens to add in para. 7 noting that "Applicant has filed this petition under Section 528 of BNSS challenging the order dated 13.12.2024 passed by the trial court whereby cognisance for the offence u/s 500 of IPC has been taken and summoning the applicant has been passed by the trial court. The applicant has expressed his regret for the alleged defamatory statement mentioned in paragraph 2 of I.A. No. 14821/2026, and the respondent has filed a reply to the said I.A. in which it is mentioned that in view of the regret expressed by the applicant, the proceedings before this Court and trial court be closed.”
Key Points from Paragraph 7
- The petition was filed under Section 528 of BNSS.
- The challenge was to the trial court's order dated 13.12.2024.
- The trial court had taken cognisance under Section 500 of IPC.
- The applicant expressed regret through I.A. No. 14821/2026.
- The respondent accepted the regret and sought closure of proceedings.
Cornerstone of the Judgment
Most significantly and so also most commendably, the Bench encapsulates in para 8 what constitutes the cornerstone of this notable judgement, postulating precisely that, “Considering the statement of applicant mentioned in I.A. No. 14821/2026 and the reply filed to the aforesaid IA as well as arguments advanced by learned counsel for both the sides wherein regret has been expressed by applicant, the proceedings before this Court are closed and proceedings pending before the JMFC, Special Judge (MP & MLA) complaint case no. SCPPM No. 03/2018 Bhopal shall also stand closed.”
Court Directions in Paragraph 8
| Issue | Court's Finding |
|---|---|
| Applicant's regret | Accepted and taken into consideration. |
| Respondent's reply | Accepted the regret and sought closure of proceedings. |
| High Court proceedings | Ordered to be closed. |
| Trial Court proceedings | Complaint Case No. SCPPM No. 03/2018 before the JMFC, Special Judge (MP & MLA), Bhopal, was also ordered to stand closed. |
Petition Disposed Of
It would be worthwhile to note that the bench notes and holds in para 9 that, “With the aforesaid, the present petition stands disposed of."
Directions to the Trial Court
Finally, the Bench then aptly concludes by directing and holding in para 10 that a copy of this order be sent to the concerning trial court for information and necessary compliance. Certified copy today.”
Summary of Final Directions
- The petition stands disposed of.
- A copy of the order shall be sent to the concerned trial court.
- The trial court shall take necessary steps for compliance.
- Certified copy to be issued on the same day.
Sanjeev Sirohi, Advocate,
s/o Col (Retd) BPS Sirohi, A82, Defence Enclave,
Sardhana Road, Kankerkhera, Meerut – 250001, Uttar Pradesh.

