Supreme Court Refuses to Interfere With HC Order Initiating Perjury Proceedings Against Manipal Business Solutions
The Supreme Court on Tuesday refused to interfere with a May 4, 2026 order of the Delhi High Court directing initiation of perjury proceedings against Manipal Business Solutions Pvt. Ltd. The proceedings stem from allegations that the company relied on false pleadings and prima facie fabricated documents in a commercial dispute with Aurigain Consultants Pvt. Ltd.
While directing initiation of proceedings under Sections 340 and 195 of the Criminal Procedure Code (CrPC), the Delhi High Court observed that a prima facie case of false averments had been made out against the company.
The Court held, “The test is not merely whether the Plaintiff entered the witness box but whether false statements, knowingly made and verified, were placed before this Court with the intent to secure favourable orders, thereby impacting the sanctity of judicial proceedings.”
A Bench of Justices Vikram Nath, V. Mohana and Sheel Nagu found no grounds to entertain the challenge to the High Court's order.
Background
Manipal Business Solutions Pvt Ltd had filed a civil suit against Aurigain Consultants Pvt Ltd and several former employees alleging breach of Non-Disclosure Agreements (NDAs), misuse of confidential information and employee poaching. The company claimed that the former employees had joined a competing business and were unlawfully using confidential information acquired during their employment. Based on these allegations, it secured an ex parte interim injunction from the Delhi High Court in April 2022.
Aurigian Consultants subsequently alleged that the injunction had been obtained through false pleadings and misleading documents. They contended that several employees had never signed the NDAs relied upon by the plaintiff, while some employees accused of violating the agreements had in fact rejoined the plaintiff company. The suit was later withdrawn by Manipal, following which Aurigain Consultants sought initiation of perjury proceedings under Sections 340 and 195 CrPC.
Allowing the application, the Delhi High Court observed that Manipal's pleadings were inconsistent with its own records and that a prima facie case of false averments had been made out. The High Court had further observed that Manipal's own conduct went beyond a mere discrepancy in evidence and struck at the integrity of the judicial process itself.
Holding that the allegations directly affected the administration of justice, the High Court directed the Registrar General to file a complaint before the competent court under Sections 340 and 195 CrPC for appropriate action against the plaintiff.