Recently, the Rajasthan High Court delivered a significant order addressing growing concerns over repetitive and abusive litigation. A Division Bench comprising Acting Chief Justice Sanjeev Prakash Sharma and Justice Baljinder Singh Sandhu examined whether a former public-sector bank officer had misused judicial forums over several years, ultimately invoking the Rajasthan Vexatious Litigation (Prevention) Act, 2015.
The case arose from an application filed by a public-sector bank seeking a declaration that its former officer had habitually launched unfounded legal and criminal proceedings. According to the bank, the individual who had served for decades before being compulsorily retired repeatedly filed complaints, FIRs and petitions across various police stations whenever disciplinary action was taken against him.
These filings spanned at least nine police stations across Rajasthan, including in Jaipur, Jodhpur, Udaipur, Alwar and Dausa. Even after closure reports were issued, he filed protest petitions and later revision petitions, prolonging proceedings and compelling numerous bank officers to defend themselves repeatedly.
The bank contended that the litigations were neither isolated nor genuine but part of an ongoing pattern aimed at obstructing internal action and harassing staff members. It argued that even after compulsory retirement in 2015, the individual continued filing fresh complaints, displaying a consistent misuse of legal machinery.
The former officer, appearing in person, maintained that his complaints were driven by legitimate grievances and by his attempts to highlight irregularities within the bank. He denied any intention to harass and asserted that he had acted only to safeguard his rights.
The Bench observed that the 2015 Act is designed to prevent abuse of judicial processes by persons who habitually initiate baseless litigation. The Court noted that the individual’s pattern of multiple FIRs based on similar allegations across different districts, followed by protests and revision petitions, demonstrated that such proceedings were not bona fide.
Citing guiding principles laid down by the Supreme Court on frivolous litigation, the Bench remarked that courts must look beyond the face of complaints and assess surrounding circumstances, especially when litigation appears driven by retaliation. According to the Court, the long sequence of filings, their geographical spread, and their timing in relation to disciplinary actions cumulatively reflected misuse of judicial forums.
The Bench held that the statutory test under Section 2 of the Rajasthan Vexatious Litigation (Prevention) Act, 2015 was clearly met. The former officer was declared a vexatious litigant, and the Court barred him from initiating or continuing any civil or criminal proceedings in the High Court or any subordinate court without prior leave.
Existing cases filed by him cannot proceed without such permission. The order will be published in the official gazette, with copies circulated to subordinate courts. A pending application under Section 340 CrPC was also closed, and the bank’s writ petition was allowed.
Case Title: State Bank of India & Anr. v Babu Lal Meena
Case No.: Civil Writ Petition No. 7169/2016
Coram: Hon’ble Mr Acting Chief Justice Sanjeev Prakash Sharma and Hon’ble Mr Justice Baljinder Singh Sandhu
Counsel for the Appellant: Sr. Adv. AK Sharma, Adv.Madhav Dadhich, Adv. Suruchi Kasliwal Adv. Vikram Singh, Adv. Annika Anna, Adv. Aayushi Jain
Counsel for the Respondent: Babu Lal Meena, respondent present-in-person
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