The Madhya Pradesh High Court has dismissed a plea filed by Satish Sanpal, a Dubai-based businessman known for his appearance on the Netflix series 'Desi Bling', seeking to quash an FIR registered against him in connection with an alleged IPL betting racket. The bench comprising Justice Himanshu Joshi considered the matter after Sanpal challenged the criminal proceedings initiated on the basis of the FIR, which named him as the mastermind of the alleged betting operations linked to the Indian Premier League.
The court, in its order, observed that upon consideration of the entire material available on record, it was of the considered view that the present case did not fall within any of the categories warranting the exercise of inherent jurisdiction for quashing the FIR or the consequential criminal proceedings. It emphasized that the contentions raised by the petitioner essentially related to the appreciation of evidence and the merits of the prosecution case, which cannot be adjudicated at this stage. Consequently, no ground was made out for quashing the FIR.
According to the facts presented, the police had received information regarding illegal IPL-related betting activities and conducted a raid at the residence of co-accused Sunil Thakur. During the raid, Sunil Thakur and Deepal Patel were found engaged in betting operations. The investigation further revealed that Satish Sanpal was alleged to be the mastermind of the racket, having opened fake shell companies in his own name and in the names of other persons to conduct large-scale transactions and defraud the government.
The counsel for Sanpal argued that the entire case was founded on suspicion and inadmissible statements recorded under Section 161 of the Code of Criminal Procedure. It was submitted that no material was collected during the investigation showing his active participation, conspiracy, or financial transactions. The counsel contended that the alleged shell companies were genuine, regularly filing statutory returns including income tax and GST returns. It was further argued that the directors of the company Laakshya, including Manoj Kumar Sanpal, whose statement had implicated Sanpal, had themselves been acquitted in connected proceedings involving similar allegations. The plea also highlighted that the alleged amount of ₹21 lakhs was neither recovered from Sanpal nor at his instance, and there was no material showing that he had committed any conscious act of printing, publishing, disseminating, or attempting to disseminate any digits, figures, signs, symbols, or pictures having a nexus with the alleged gambling activity.
The counsel for the State countered that the evidence collected during the investigation ought to be examined at the trial stage. It was argued that the order passed in favour of a co-accused, Sanjay Sanpal (referred to in the plea as having been granted relief on May 6, 2025), was based on particular facts and did not entitle Sanpal to similar relief. The State maintained that the investigation was entitled to trace the source of the offence and implicate other persons who came to light during the inquiry.
The bench, while examining the matter under the inherent jurisdiction of Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), clarified that it is not permitted to scrutinise the entire evidence meticulously at this stage. Its role is limited to examining whether the evidence prima facie establishes the offence. The court noted that the evidence on record indicated involvement of Sanpal in the alleged betting activities.
The bench further emphasized that merely because the petitioner disputed the said material or offered an explanation in respect thereof could not be a ground for quashing the criminal proceedings at this stage. It rejected Sanpal’s objection that he was not present in the country at the time of the offence, noting that the proceedings claimed his involvement through other persons, companies, and other means.
The court also rejected the objection that Sanpal was not named in the FIR or initial documents, highlighting that an FIR is not expected to contain the entire prosecution case or the names of every person who may ultimately be found involved in the commission of the offence. It stated that the investigating agency is entitled to investigate the source of the offence and the role of other persons who subsequently come to light during the investigation. The mere subsequent implication of the petitioner, therefore, could not be a ground for quashing the proceedings.
The court concluded that no case was made out for exercising its inherent jurisdiction to quash the FIR, and the petition was accordingly dismissed. The criminal proceedings against Satish Sanpal will now proceed to trial based on the evidence collected during the investigation.