The Madhya Pradesh High Court has formally denied a request to return a seized Oath Commissioner ’s register, citing ongoing investigations into serious allegations of fraud. The decision comes after an internal inquiry revealed that the register contains vital evidence regarding the submission of forged affidavits and unauthorized legal documentation filed before the court.

Justice Deepak Khot, presiding over the matter, underscored the gravity of the situation during the hearing. The court noted that the Registrar had conducted an independent investigation into the provenance of documents filed in connection with an appeal. The inquiry, dated September 24, 2026 , confirmed that several documents, including the appellant’s own affidavits , were prima facie fraudulent.

Evidence Seized in Fraud Investigation The register in question had been seized in August 2026 under specific judicial orders as part of a wider investigation into potential malpractice. The Oath Commissioner , Laxmi Devi Singh, had personally appeared before the bench to seek the return of the register. However, the court determined that the integrity of the judicial process necessitated its continued retention by the registry.

The findings presented to the court were stark. During the probe, the Oath Commissioner admitted that a counsel who purportedly appeared before her for the attestation of an affidavit had, in fact, never attended the proceedings. This admission provided the catalyst for the court’s refusal to release the records. As Justice Khot stated in the order, "On perusal of the enquiry report dated 24.9.2026, it is found that the Registrar has Prima Facie found that fraud has been committed with the court by filing various documents including affidavits of the appellant."

Allegations of Unauthorized Representation The dispute stems from a complex procedural history involving the appellant’s legal representation. The original appeal was filed through a consortium of multiple advocates, including S.P. Mishra , Falguni Yadav , Jitendra Mohan Sharma , Shailendra Kumar Patel , Joydeep Bhattacharya , Satyartha Balaji Sinha , and Surendra Kumar .

A significant breach of procedure occurred on August 5, 2026 , when a new vakalatnama was introduced, purportedly signed by a different advocate, Ajay Kumar Yadav . This filing included an alleged No Objection Certificate ( NOC ) attributed to S.P. Mishra . When the court confronted the appellant with these documents, the appellant, appearing alongside Advocates Bhattacharya and Mishra, provided her passport to confirm her identity and explicitly denied any knowledge of Ajay Kumar Yadav . She testified that she had never executed the contested vakalatnama . Mishra similarly testified that he had never authorized the issuance of the purported NOC .

Judicial Consequences and Next Steps The discovery of these discrepancies has triggered a robust judicial response. Because the register is now considered a key piece of evidence in the ongoing criminal inquiry, the court ruled that it cannot be surrendered. The Registrar has already initiated the necessary protocols for the formal registration of a First Information Report ( FIR ) to address the alleged acts of fraud against the court.

Regarding the register's status, the court was definitive, noting: "In such circumstances, in the considered opinion of this Court, the Register cannot be returned back to the applicant because it has become a piece of evidence and the Registrar has already initiated proceeding for registration of FIR for the alleged fraud."

The court has effectively closed the miscellaneous application ( PUD ) regarding the register’s return. The underlying appeal has been scheduled for further hearing in the week commencing November 30, 2026 . In the interim, the court has ordered that existing interim relief measures remain in effect until the next date of hearing, ensuring that the procedural integrity of the main case is maintained while the investigation into the fraudulent filings proceeds. The court’s firm stance serves as a warning against the manipulation of legal documents, reinforcing the necessity of strict compliance with filing protocols to protect the sanctity of the judicial system.