Delhi High Court Orders Perjury Proceedings Against Manipal Business Solutions Over Alleged Fabricated Documents

The Delhi High Court has directed initiation of prosecution proceedings against Manipal Business Solutions over alleged false statements and use of allegedly fabricated documents in court proceedings against its former employees.

The court found a prima facie case that the company made false claims in its lawsuit against employees alleged to have joined rival firm Aurigain Consultants.

Explaining why it warranted criminal action, the court held,

“Accordingly, this Court is of the opinion that the ingredients of Section 195(1)(b)(i) CrPC are attracted, as the alleged false statements form part of the judicial record and have a direct bearing on the administration of justice. 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.”

Justice Subramonium Prasad directed the Registrar General to file a complaint before the competent court.

The case arose from a suit filed by Manipal seeking an injunction and damages of over ₹10 crore against Aurigain Consultants and several employees, alleging breach of confidentiality obligations, misuse of confidential information, and operating a competing business.

Manipal claimed that the employees had access to confidential business information during their employment and were bound by non-disclosure agreements restricting disclosure after resignation. It alleged that some employees resigned, joined Aurigain, and encouraged others to leave and join the rival company.

The High Court had granted interim relief to Manipal in April 2022, but later vacated that order. Manipal subsequently withdrew the suit.

Aurigain later sought action against Manipal, alleging that it had secured interim relief by making false statements and placing false material before the Court.

The Court said such prosecution can be initiated where false statements or forged documents in judicial proceedings affect the administration of justice and the interests of justice require action.

“A prima facie case is, therefore, made out that false averments have been made in the Plaint. The pleadings are found to be inconsistent with the documents placed on record by the Plaintiff itself. The documentary record revealed that Defendant Nos.5-7 and 12-20 had not signed the NonDisclosure Agreements relied upon by the Plaintiff.”

The court noted that several defendants had not signed the non-disclosure agreements relied upon by Manipal. While some later admitted executing such agreements, one defendant specifically alleged that his signatures had been forged.

Holding that the alleged false statements formed part of the judicial record and directly affected the administration of justice, the Court directed initiation of prosecution proceedings.

For Plaintiff: Senior Advocate Malavika Trivedi, Advocates Atanu Mukherjee, Sujal Gupta and Shailendra Slaria

For Defendants: Advocates Shantha Devi Raman, Arihant Jain, Tanisha Gopal and RK Singh