On May 3, 2025, the Supreme Court of India confirmed the conviction of three individuals for creating and using fake court orders allegedly issued by the Madras High Court. The judgment in Shanmugam Lakshminarayanan v. High Court of Madras was delivered by a Division Bench comprising Justice Sudhanshu Dhulia and Justice Prashant Kumar Mishra. The Apex Court held that such actions not only obstruct the justice delivery system but also amount to a serious offence of contempt of court.
The case arose after the convicted persons presented fake court orders to stop the execution of a civil decree. Upon investigation, it was found that the forged documents were produced with the intent to mislead the court and gain an unfair advantage. Recognizing the gravity of the act, the Supreme Court stated that fabricating judicial documents is among the most dangerous forms of contempt of court.
By affirming the High Court’s findings, the Supreme Court emphasized that fake court orders not only undermine public trust but also involve deliberate forgery, which deeply damages the integrity of the justice system. Though the conviction was upheld, the sentence was reduced from six months to one month of simple imprisonment, acknowledging mitigating factors. This blog covers a Supreme Court case on punishment for using fake court orders as contempt of court.
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Factual Background of Fake Court Orders Case
The case stems from a civil dispute where the District Munsiff Court, Tiruchengode, passed a decree in favour of the J.K.K. Rangammal Charitable Trust, directing recovery of property and arrears of rent from three individuals who are now contemnors. After their appeal suits were dismissed, the Decree Holder filed an Execution Petition to take possession of the property.
On May 15, 2018, when the court-appointed Amin went to execute the decree, the contemnors produced interim orders, supposedly issued by the Madras High Court, staying the execution. On investigation, it was revealed that the documents were forged, involving impersonation of a High Court judge. The forged documents were created in a local internet café with help from one of the accused.
The High Court later found that the accused had knowingly used fake court orders to mislead the execution court and stop the delivery of justice. This deliberate act of forgery was considered a clear case of contempt of court. The CBCID investigation and affidavits from the accused confirmed their role in preparing and using these forged judicial documents.
The High Court convicted all three contemnors and sentenced them to six months of simple imprisonment. However, by the time the case reached the Supreme Court, two of the accused had passed away, and the case continued only against the third. The Supreme Court upheld the conviction but reduced the sentence to one month of imprisonment.
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Applicable Legal Provisions
The case involved both criminal offences under the Indian Penal Code (IPC) and proceedings under the Contempt of Courts Act, 1971, due to the creation and use of fake court orders.
Under the Indian Penal Code, 1860 (IPC)
- Section 466 IPC: Forgery of record of a court or public register.
This section applies when someone forges a document pretending it to be a court order. In this case, the fake court orders presented were forged in the name of a High Court judge. - Section 468 IPC: Forgery for the purpose of cheating.
Since the fake orders were used to deceive the Execution Court and delay delivery of possession, this section directly applies. - Section 471 IPC: Using a forged document as genuine.
Even if the accused did not personally create the fake orders, using them knowingly is a punishable offence under this section.
These IPC sections were part of FIR No. 8 of 2018, filed by the District Crime Branch, Namakkal, against the three contemnors.
Under the Contempt of Courts Act, 1971
- Section 15(1): Procedure for taking cognizance of criminal contempt.
This section allows the High Court to take suo motu action or act on a reference from a subordinate court or government. In this case, the High Court took cognizance of the matter based on the writ petition filed by the decree holder. - Section 18(1): Hearing of criminal contempt to be by a Bench of not less than two Judges.
Following proper procedure, the matter was placed before a Division Bench of the High Court for hearing the criminal contempt case. - Section 2(c): Defines criminal contempt, which includes interference with or obstruction of the administration of justice. Producing fake court orders clearly falls under this category.
- Section 12: Punishment for contempt of court.
The contemnors were sentenced to simple imprisonment, as allowed under this section, which provides for punishment by imprisonment, fine, or both.
Court’s Reasoning on Fake Court Orders and Contempt of Court
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The Supreme Court upheld the findings of the Madras High Court after thoroughly examining the case materials, including the CBCID report and the affidavits filed by the contemnors. The Bench observed that the High Court had based its decision on “cogent and reliable material available on record,” and had rightly concluded that the contemnors deliberately used fake court orders to interfere with the execution of a lawful decree. This act, the Court said, was not based on suspicion or probability but proved beyond all reasonable doubt.
The Bench took note of the continuous chain of events starting from 2018, when the fake court orders were first produced during the court-ordered possession process. The judges concluded that the case was not merely a technical violation but a deliberate act aimed at disrupting the justice delivery system thereby amounting to criminal contempt of court. In a strong statement reaffirming the seriousness of the offence, the Supreme Court remarked:
“The sole object of the Court wielding its power to punish for contempt is always for maintaining the purity of administration of justice. Nothing is more incumbent upon the courts of justice than to preserve their proceedings from being misrepresented, nor is there anything more pernicious when the order of the court is forged and produced to gain undue advantage.”
This remark highlights that producing fake court orders strikes at the heart of judicial credibility. It misleads courts, obstructs the rule of law, and manipulates outcomes that affect real people. The Court emphasized that any person using such documents whether or not they created them then they can still be held guilty of contempt of court.
Further, the Court held:
“When a person is found to have utilised an order of a court which he or she knows to be incorrect for conferring benefit on persons who are not entitled to the same, the very utilisation of the fabricated order by the person concerned would be sufficient to hold him/her guilty of contempt, irrespective of the fact whether he or she himself or herself is the author of fabrication.”
This legal reasoning firmly establishes that even using fake court orders knowingly is enough to attract punishment for criminal contempt.
The Court also addressed a procedural question whether the contempt action was barred by limitation. It clarified that action was initiated on September 5, 2018, when the Single Judge referred the matter for contempt proceedings, which was within one year of the forgery being detected. Hence, the contempt case was legally valid.
Finally, while confirming the conviction, the Supreme Court took a lenient view in terms of sentence. Instead of upholding the full six-month jail term given by the High Court, it modified the punishment to one month of simple imprisonment for the surviving contemnor, considering the overall facts.
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Implication of the Judgment
- The judgment sends a strong warning that using or creating fake court orders is a serious offence and will lead to punishment.
- The Court confirmed that such actions amount to criminal contempt of court, as they damage the credibility of the judicial system.
- Even if someone did not create the fake document but knowingly used it, they can still be held guilty of contempt of court.
- This decision reinforces that forgery of court records is a direct threat to the rule of law and cannot be ignored.
- It protects the integrity of court proceedings and ensures that people cannot misuse the legal process to gain illegal benefits.
- The ruling helps maintain public trust in the judiciary by showing that fake court orders will be dealt with seriously.
Final Thoughts
The Supreme Court’s decision in this case highlights the grave consequences of using fake court orders to obstruct justice. By upholding the conviction for contempt of court, the Court reinforced that any attempt to mislead the legal system whether through forgery or misuse of judicial documents will not go unpunished. This judgment not only protects the sanctity of court proceedings but also sends a clear message that justice cannot be manipulated through fraud.
