SHISHIR CHAND v. JAI ANANT DEHADRAI & ANR.

CRL.M.C. 1780/2024 Page 1 of 21

$~7(Appellate)

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 08.10.2026 # CNR No. DLHC010100282024 + CRL.M.C. 1780/2024, CRL.M.A. 6798/2024, CRL.M.A.

7709/2024, CRL.M.A. 24550/2026 & CRL.M.A. 25055/2026 SHISHIR CHAND .....Petitioner Through: Petitioner in person.

versus

JAI ANANT DEHADRAI & ANR. .....Respondents Through: Respondent no. 1 in person, with Ms. Yashvi Aswani and Mr. Ram Pravesh Dubey, Advocates for R-1.

CORAM:

HON’BLE DR. JUSTICE SWARANA KANTA SHARMA

JUDGMENT

DR. SWARANA KANTA SHARMA, J. (Oral)

CRL.M.A. 24550/2026 (seeking release of matter) & CRL.M.A.

25055/2026 (filing additional documents)

1. By way of CRL.M.A. 24550/2026, the petitioner, appearing in person, seeks release of the present matter, i.e. CRL.M.C. 1780/2024, from this Bench – in view of the constitution of a fresh roster of Benches with effect from 01.07.2026. The applicant has soug ht such release primarily on the ground that this Court, on 28.07.2026, had released certain other criminal matters, including CRL.M.C. No.

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14/2025 and W.P. (Crl.) No. 1744/2024, and has, accordingly, sought similar treatment in the present case.

2. On the ot her hand, by way of CRL.M.A. 25055/2026, the respondent no. 1 seeks permission to place on record additional documents, and inter alia, seeks initiation of proceedings for criminal contempt of court against the petitioner.

3. Briefly stated, the present proce edings arise out of disputes between the applicant/petitioner and respondent no. 1, a practising advocate, who had earlier represented the petitioner in proceedings concerning the death of his younger brother, Vishal Chand, and the alleged irregularities relating to the medical qualifications of one Atul Chhabra. The petitioner has alleged that respondent no. 1 withdrew from his representation shortly before a crucial hearing in W.P. (C)

No. 277/2017, following which disputes arose between them concerning t he conduct of the proceedings and the professional obligations of respondent no. 1. The petitioner thereafter initiated various proceedings against respondent no. 1, alleging professional misconduct and other irregularities, while respondent no. 1 also instituted criminal defamation proceedings against the applicant. The ensuing disputes have given rise to several proceedings before different judicial and statutory forums, including the present proceedings.

4. It is also pertinent to note that this Court had h eard arguments in the matter on 21.01.2026, when the matter was ‘part -heard’, and thereafter on 28.07.2026. The present application, therefore, arises in

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the context of a matter in which substantial judicial time had already been devoted to the hearing, an d the applicant's request for release falls for consideration against the backdrop of the subsequent change in roster and the release of other criminal matters by this Court.

Submissions on Behalf of the Petitioner

5. The petitioner, appearing in person, subm its that the application filed by him, is confined to the limited prayer for release of CRL.M.C. No. 1780/2024 from the present Bench in view of the fresh roster which came into effect on 01.07.2026. He submits that, following the change in roster, this Co urt, on 28.07.2026, released certain other criminal matters and, therefore, the present matter also merits consideration for release and placement before the Bench having the appropriate roster. He emphasises that the request is founded on the change in ro ster and the subsequent release of other criminal matters, and does not seek any adjudication on the merits of the underlying dispute.

6. The petitioner submits that the allegations against respondent no. 1 and the rival claims arising from their previous pr ofessional relationship are not required to be examined for deciding the limited prayer made in the present application. In the alternative, he prays that, if the request for release is declined, the basis for continued listing of the matter before the pre sent Bench, notwithstanding the change in roster and release of the aforesaid matters, be clarified.

7. In the contents of the present application, the petitioner sets out

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the background of his grievances against respondent no. 1, tracing their genesis to the latter’s engagement as his counsel in proceedings arising out of the death of his younger brother, Vishal Chand, and the alleged irregularities concerning the medical q ualifications of Atul Chhabra. He states that he had engaged respondent no. 1 to pursue proceedings before this Court, including W.P. (C) No. 277/2017, concerning the medical qualifications of Atul Chhabra and the circumstances surrounding his brother's de ath. He submits that respondent no. 1 withdrew from his representation on 29.08.2017, shortly before the hearing scheduled for 30.08.2017, leaving him without legal assistance at a crucial stage. He alleges that, thereafter, forged and fabricated documents concerning the medical degree of Atul Chhabra were placed before the Court and that the order dated 30.08.2017 passed in the said writ petition was consequently vitiated by misrepresentation and was subsequently relied upon in other proceedings, causing p rejudice to him. The petitioner further states that the order dated 30.08.2017 was challenged in LPA No. 693/2017 and SLP (C) No. 41865/2018, but without any relief to him. He submits that the consequences of the said order extended to proceedings concerning FIR No. 164/2014, registered under Section 304 of IPC in relation to the death of his younger brother, and alleges that the CB -CID, Jharkhand, filed a final report on 06.07.2018, relying upon the said order in bringing the investigation to a close.

According to the petitioner, the circumstances surrounding respondent no.1’s withdrawal, the subsequent events in W.P. (C) No.

277/2017 and the reliance placed upon the order dated 30.08.2017 in

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other proceedings form part of the background to his grievances against respondent no. 1. The petitioner also refers to subsequent proceedings concerning the alleged discrepancies in the educational qualifications of Atul Chhabra, including Cont. Case (C) No.

839/2019, in which this Court issued notice on 24.05.2022, an d proceedings under Section 340 of Cr.P.C. stated to have been initiated on 10.05.2024 against the General Manager, Tata Steel, Atul Chhabra and the Registrar, Ranchi University, in relation to the alleged misrepresentation concerning the medical degree. He submits that these proceedings remain pending and form part of the continuing litigation arising out of the same underlying controversy.

He further states that his grievances have subsequently extended to the conduct of respondent no. 1 and the manner in which the proceedings were pursued.

8. The petitioner also refers to the criminal defamation proceedings instituted by respondent no. 1 against him, which, according to him, remain pending at the stage of cross -examination since July 2024. He alleges that re peated adjournments have taken place on account of respondent no. 1's failure to submit to cross - examination. He states that, in these circumstances, he approached the Principal District and Sessions Judge, South, Saket, by filing Transfer Petition (Crl.) No. 61/2026, wherein notice was issued on 05.06.2026 and comments were sought. He further refers to his own criminal complaint, being CT/2517/2024, against respondent no. 1, in which proceedings under Section 200 of Cr.P.C. have been initiated

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and pre-summoning evidence was directed to be recorded vide order dated 12.06.2025. He also refers to Criminal Revision No. 325/2025, whereby he has sought investigation by the Crime Branch into the alleged larger conspiracy. According to the petitioner, these proceedings form part of the wider series of disputes between the parties and provide the context in which the present proceedings have arisen.

9. With regard to the social -media posts relied upon by respondent no. 1, the petitioner submits that the same ought not t o be considered in isolation from the background of the prolonged disputes between the parties. He contends that the posts reflect his longstanding grievances concerning the death of his brother, the alleged irregularities relating to the medical qualifica tions of Atul Chhabra and the subsequent proceedings pursued by him and his family members before various judicial and statutory authorities. He also refers to various complaints and proceedings instituted against respondent no. 1 alleging professional mis conduct. In this regard, he relies upon the order dated 19.12.2023 passed by this Court in W.P.

(C) No. 11820/2021, whereby the order of the Central Information Commission restricting his filing of further RTI second appeals was set aside. According to the petitioner, the said order is also relevant to the background of his efforts to pursue the issues raised by him before statutory authorities. He, therefore, submits that the social - media posts and the allegations arising therefrom have to be viewed in the context of the aforesaid history of litigation.

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10. The petitioner, thus, reiterates that the present application does not seek any determination on the correctness of the allegations raised by either party or reopening of the underlying disputes. He submits that his prayer is confined to release of CRL.M.C. No.

1780/2024 from the present Bench in view of the fresh roster effective from 01.07.2026 and the release of other criminal matters by this Court on 28.07.2026. He contends that the request for release is a distinct procedural issue and that the allegations concerning his conduct, the social -media posts relied upon by respondent no. 1 and the rival claims arising from their previous professional relationship ought not to prejudice consideration of the limi ted relief sought. He accordingly prays that the matter be released and placed before the Bench having the appropriate roster, leaving all questions concerning the merits of the underlying dispute and the respective rights and contentions of the parties open.

Submissions on Behalf of Respondent No. 1 11. Respondent no. 1, appearing in person, opposes the application filed by the petitioner, and submits that the application i.e. CRL.M.A.

25055/2026 filed by respondent no. 1 is necessitated by the persistent conduct of the petitioner, who has repeatedly instituted frivolous, vexatious and multiplicious proceedings against him, before various courts, tribunals and regulatory fora. He submits that the present proceedings cannot be viewed in isolation but are requir ed to be considered in the backdrop of the petitioner’s consistent conduct of initiating successive proceedings against respondent no. 1 and other

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members of the Bar, thereby subjecting them to unnecessary litigation and harassment.

12. Respondent no. 1 submi ts that, over a considerable period, the petitioner has made abusive, intemperate and scandalous remarks on various social-media platforms against sitting and former Judges of the Hon’ble Supreme Court of India and this Court, including the Chief Justice o f India, besides other constitutional functionaries and elected women representatives. He contends that the nature and tenor of these posts, several of which are placed on record as Annexure B, disclose a sustained pattern of derogatory allegations against members of the judiciary and other public functionaries. In this regard, he relies upon the order dated 05.02.2023 passed by the learned Additional Sessions Judge in Criminal Revision No.

302/2023, particularly paragraph 25 thereof, wherein observations have been made concerning the petitioner’s propensity to malign and bring disrepute to the Indian Judiciary and its Judges.

13. Respondent no. 1 further submits that the petitioner’s conduct is not confined to criticism of judicial orders or expression of grievances in pending proceedings but extends to offensive and derogatory remarks against individual Judges and women occupying public offices, including elected representatives. He contends that such remarks reveal a continuing pattern of personal attacks and are relevant to appreciating the petitioner’s conduct in the present proceedings. Respondent no. 1 also submits that the social -media posts placed on record are relevant in the context of the petitioner’s

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allegations concerning alleged manipulation of the constitution of Benches and his purported allegations against respondent no. 1 in relation thereto. He contends that the petitioner has repeatedly levelled allegations of bench fixing and judicial impropriety against judicial officers and has sought to att ribute the same to respondent no. 1, who had earlier represented him in certain proceedings.

According to respondent no. 1, the posts are relied upon not as proof of the truth of the allegations concerning bench fixing, but to demonstrate the petitioner’s narrative, the background in which such allegations have been made and the animus allegedly underlying his actions against respondent no. 1.

14. Respondent no. 1 submits that the petitioner has, in the course of the present proceedings, made disparaging remarks concerning the fairness of the Judge hearing the matter and has sought release of the case from the present Bench. He contends that the pre sent application, when viewed alongside the petitioner’s social -media posts and allegations against judicial officers, amounts to an attempt to exert pressure upon the judicial process and that allegations against the presiding Judge cannot be permitted to become a means of securing a change of Bench. Respondent no. 1 draws attention to the compilation of proceedings annexed as Annexure C and submits that the petitioner has instituted numerous cases and complaints against him before different courts and for a, including the Bar Council of Delhi, the Bar Council of India, the District Courts at Saket and this Court. He contends that the proceedings enumerated therein,

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including complaints, revision petitions, transfer petitions and civil proceedings, demonstrate a pattern of repetitive litigation which has caused him considerable inconvenience and compelled him to devote substantial professional time and resources towards defending himself.

15. Respondent no. 1 submits that he is an Advocate -on-Record of the Supreme Court of India and has been in active legal practice for more than fifteen years before the Supreme Court, this Court, the District Courts and various other judicial and quasi -judicial fora.

According to him, the repeated institution of proceedings against him has adversely affected his professional commitments and caused unnecessary expenditure of time, effort and resources, to the prejudice of his clients.

16. Respondent no. 1 further submits that the documents which have been placed on record by him are ma terial for appreciating the circumstances in which the present proceedings have been instituted and the conduct of the petitioner towards him. He contends that the social-media posts and particulars of the various proceedings are relevant to the background of the dispute and the petitioner's previous and subsequent conduct. In support, he relies upon Sections 6, 7, 9 and 12 of the Bharatiya Sakshya Adhiniyam, 2023. Respondent no. 1 also submits that the contents of the social -media posts, particularly those directed against Judges of the Supreme Court and this Court, prima facie disclose conduct capable of scandalising the judiciary and lowering the authority of the courts in the eyes of the public. He

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contends that such remarks go beyond permissible critici sm of judicial decisions and warrant consideration by this Court in exercise of its powers under the Contempt of Courts Act, 1971. He accordingly urges this Court to take suo motu cognizance of the alleged criminal contempt and initiate appropriate proceed ings against the petitioner, besides permitting the additional documents to be taken on record.

17. Respondent no. 1 lastly submits that the petitioner’s conduct, viewed cumulatively, demonstrates an abuse of the process of law and that the present proceedings are required to be considered in the context of the repeated allegations, social -media posts and multiplicity of litigation brought to the notice of this Court. He accordingly prays that the application filed by him be allowed, the additional documents be taken on record, appropriate proceedings for criminal contempt be considered in respect of the petitioner’s alleged conduct, and exemplary costs be imposed upon the petitioner.

18. This Court has heard the arguments addressed on behalf of both the parties, and has perused the material available on record.

Analysis & Findings

19. The question which arises for consideration is whether the present matter, which has already been part-heard by this Court, ought to be released from this Bench consequent upon the change in roster with effect from 01.07.2026.

20. Before considering the prayer for release, it would be

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appropriate to notice the significance of a matter being treated as part-heard. A matter becomes part-heard once the Court has commenced hearing and has devoted substantial judicial time to the consideration of the matter. In such a situation, the Court also, apart from hearing the submissions of the parties, applies its mind to the pleadings, documents, arguments and the issues arising for consideration. The cont inuity of the hearing before the same Bench is, therefore, intended to avoid duplication of judicial effort and the investing further judicial time which may become necessary if the matter is required to be heard afresh by another Bench. The concept of a part-heard matter thus serves an important purpose in the orderly and efficient administration of judicial work. As a result, even a change of roster permits the previous Bench to retain a matter which has already been part-heard.

21. Undoubtedly, the allocati on of judicial business through a roster is an administrative function, and the prerogative of the Hon’ble Chief Justice, but the question whether a matter which has been categorised as part-heard should continue before the same Bench, or be released for b eing placed before the Bench having the roster, is a matter which has to be considered in the facts and circumstances of the case, by the concerned Bench only. The extent of hearing already undertaken, the judicial time invested, the stage of the proceedin gs and the applicable roster are all relevant considerations in this regard.

22. Thus, even after a fresh roster comes into operation, a Court

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may, in an appropriate case, retain a matter which has already been heard substantially. Conversely, a matter may al so be released and placed before the Bench having the roster in question. There can, therefore, be no inflexible rule that every part-heard matter must necessarily remain before the same Bench after a change in roster, or that every such matter must necess arily be released upon the constitution of a fresh roster. The question remains one for the Court to determine having regard to the circumstances of the particular matter.

23. In the present case, this Court had heard the matter on 21.01.2026, when the order sheet recorded the matter as ‘part-heard’.

The matter was also taken up and heard on 28.07.2026. The petitioner has placed considerable reliance on the fact that this Court, on 28.07.2026, released certain other criminal matters, including CRL.M.C. 14/2025 and W.P. (CRL.) 1744/2024.

24. In this Court’s opinion, the mere release of those matters cannot by itself create a right in favour of the petitioner to seek, as a matter of right, an identical order. The circumstances, stage of hearing and procedural history of each matter may be different, unknown to the present petitioner. An order releasing one matter cannot, therefore, be treated as laying down a general rule requiring the release of every other matter which is similarly placed in some respects. The Court must also guard against a situation where the process of seeking release of a matter may be used as a means of repeatedly seeking a change of Bench, delaying the proceedings or

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attempting to secure a forum perceived to be more favourable.

Needless to say, the choice of the Bench before which a matter is to be heard cannot be left to the preference of a litigant. The independence and orderly functioning of the judicial process require that the allocation and continuation of judicial business remain governed by the applicable institutional arrangements and orders of the Court.

25. It is in this context that the material placed on record by respondent no. 1 also requires to be noticed. By way of CRL.M.A.

25055/2026, respondent no. 1 has sought permission to place additional documents on record, which principally include a compilation of social -media posts attributed to the petitioner, apart from material concerning various proceedings instituted by the petitioner against respondent no. 1 and others.

26. For the sake o f clarity, a table prepared and filed on record by respondent no. 1, concerning the names of the persons against whom the petitioner has levelled allegations, which includes several Judges of the Hon’ble Supreme Court as well as this Court, is set out below:

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CRL.M.C. 1780/2024 Page 16 of 21

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27. A perusal of the material placed on record shows that several of the posts published on social media by the petitioner – which the petitioner, appearing in person, admitted before this Court to having published – contain allegations against sitting and for mer Judges of the Hon’ble Supreme Court of India and this Court. Some of the posts question the integrity of judicial officers or attribute improper motives to judicial decisions, while others refer to alleged

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manipulation in the constitution of Benches, a lleged collusion with political or corporate entities and alleged extraneous considerations influencing judicial outcomes. Certain posts also contain language which is personally derogatory or offensive.

28. The material also contains posts concerning other pu blic functionaries and elected representatives, including women holding public office. Some of the expressions attributed to the petitioner are intemperate and derogatory. This Court, however, does not consider it necessary, for the purposes of the present applications, to examine each individual post or to express any final opinion regarding its authenticity, authorship, context or legal consequences.

29. It is necessary, nevertheless, to draw a distinction between criticism of a judicial order and a personal attack upon the Judge who has passed any order. A litigant is entitled to question an order, challenge its reasoning, and pursue the remedies available in law.

Such criticism, even if strongly worded, cannot merely on account of its adverse nature be equat ed with an attack upon the Judge or the institution. However, bald allegations attributing corruption, collusion, deliberate manipulation or improper motives to individual Judges stand on a different footing, particularly where such allegations are repeatedly made without any material whatsoever.

30. The material placed on record also refers to several proceedings instituted by the petitioner against respondent no. 1 and certain other persons. As noticed from Annexure C, these include proceedings before the Bar Council of Delhi, the Bar Council of

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India, the District Courts at Saket and this Court. The compilation includes complaints, revision petitions, transfer petitions, civil proceedings and writ proceedings. Respondent no. 1 relies upon this material to con tend that he has been subjected to successive and overlapping litigation. The petitioner, on his part, seeks to explain his conduct by referring to his longstanding grievances arising from the death of his brother, the alleged irregularities concerning the medical qualifications of Atul Chhabra and the subsequent proceedings pursued by him and his family members. Respondent no. 1, on the other hand, relies upon the social -media posts and the various proceedings to contend that the petitioner has repeatedly made personal allegations against him and judicial officers. Be that as it may, these rival contentions of the parties have been taken note of only to highlight the background in which the present applications have been filed. This Court is not called upon , in the present proceedings, to adjudicate upon the truth of the underlying allegations.

31. In view of the aforesaid, insofar as CRL.M.A. 25055/2026, this Court is inclined to take on record the additional documents filed by the respondent no. 1, including the compilation of social-media posts.

However, their being taken on record shall not be construed as an expression of opinion by this Court regarding the truth, authenticity, authorship or legal effect of the contents thereof.

32. Nevertheless, this Court at this stage is not inclined to initiate any proceedings relating to contempt of court against the petitioner.

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No finding is being returned as to whether any individual post constitutes criminal contempt, and the question of the legal consequences, if any, o f the material placed on record is left open to be considered in appropriate proceedings. The respondent no. 1 will be at liberty to raise any grievance in this regard by way of any other appropriate application/petition, if so advised.

33. The application, i .e. CRL.M.A. 25055/2026, is disposed of in above terms.

34. This brings the Court back to the principal prayer in CRL.M.A.

24550/2026. This Court has considered the fact that the matter is part-heard, the substantial judicial time already devoted to it, the subsequent hearing on 28.07.2026, the fresh roster which came into effect from 01.07.2026 and the fact that certain other matters were released by this Court on 28.07.2026. The Court has also considered the material placed on record by the respondent no. 1, regarding the repeated allegations made by the petitioner concerning the constitution of Benches and the fairness of judicial proceedings, against several members of the Judiciary. Such allegations, however, cannot either compel release of a matter or con stitute a ground for selecting the Bench before which the matter is to be heard.

35. Nevertheless, having regard to the overall circumstances of the present case, and particularly the fact that no specific allegation has been levelled against this Court, the relief in the present application was only sought on ground of change of Roster, and since this Court has no interest in retaining the matter before it itself, and also

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considering that this Court has a new roster which has particularly old cases and long cause list demanding time and attention, this Court considers it appropriate that the matter may be placed before the concerned Roster Bench.

36. As a sequitur, CRL.M.C. 1780/2024 is released from the category of ‘part-heard’ matters.

37. Accordingly, CRL.M.A. 24 550/2026 is disposed of in above terms.

38. It is clarified that this Court has not expressed any opinion on the merits of CRL.M.C. 1780/2024 or on the truth or otherwise of the rival allegations between the parties.

CRL.M.C. 1780/2024

39. Let the matter be list ed before the concerned Roster Bench, subject to the orders of Hon’ble the Chief Justice, on 14.10.2026.

40. The judgment be uploaded on the website forthwith.

DR. SWARANA KANTA SHARMA, J

OCTOBER 8, 2026/ns

TS