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Supreme Court Upholds Medha Patkar’s Criminal Defamation Conviction in Case Filed by Delhi LG VK Saxena, But Waives Rs 1 Lakh Fine

Supreme Court Upholds Medha Patkar’s Criminal Defamation Conviction in Case Filed by Delhi LG VK Saxena, But Waives Rs 1 Lakh Fine

On August 11, 2025, the Supreme Court of India declined to overturn the criminal defamation conviction of noted activist and Narmada Bachao Andolan leader Medha Patkar in a suit filed by Vinai Kumar Saxena, the current Lieutenant Governor of Delhi. While affirming the conviction, a bench comprising Justices MM Sundresh and N Kotiswar Singh set aside the Rs 1 lakh penalty previously imposed on her, modifying her probation conditions to ease compliance.
 
Background and Case Origins
 
The defamation suit arose from a press statement issued by Medha Patkar on November 25, 2000, titled “True Face of Patriot.” In the note, Patkar accused Vinai Kumar Saxena of involvement in illicit hawala transactions, alleged that Saxena had issued a cheque for ₹40,000 to the Narmada Bachao Andolan that bounced due to the account being non-existent, and described him as a “coward” rather than a patriot.
 
Following this, Saxena initiated a criminal defamation complaint against Patkar in 2001. After an extended legal battle, the trial court in April 2025 convicted Patkar under Section 500 of the Indian Penal Code, stating that her statements were deliberate, malicious, and intended to harm Saxena’s reputation. The court labeled the comments as defamatory per se and acknowledged the substantial damage caused to Saxena’s standing and credibility. However, the court suspended her jail sentence and instead imposed probation, granting her bail on a personal bond of ₹25,000.
 
Appeal Proceedings and Arguments
 
Medha Patkar challenged the conviction and sentencing before the Delhi High Court. Her legal team, led by Senior Advocate Sanjay Parikh, contended that the appellate court erred by disbelieving two critical witnesses supporting her defense. Further, they argued that the prosecution’s key electronic evidence—an email—was inadmissible as it lacked certification under Section 65B of the Indian Evidence Act, which is mandatory for electronic documents.
 
On July 29, 2025, the Delhi High Court upheld the trial court’s conviction. The court found no procedural irregularities or legal errors in the judgment and dismissed Patkar’s plea to summon additional witnesses, ruling that such requests did not justify interfering with the conviction. The High Court maintained the probation sentence but relaxed the requirement for Patkar’s physical presence by allowing remote appearances or representation by counsel during periodic court check-ins.
 
Supreme Court’s Judgment
 
When the matter reached the Supreme Court, the bench led by Justices MM Sundresh and N Kotiswar Singh chose not to disturb the conviction, emphasizing the seriousness of defamatory statements that damage reputations. However, the Court recognized that the penalty imposed on Patkar warranted reconsideration and consequently set aside the Rs 1 lakh fine.
 
The Court further modified the probation conditions by removing the obligation for Patkar to appear personally in court periodically and instead permitted her to furnish bonds as a form of compliance assurance.
 
Senior Advocate Maninder Singh, representing Saxena, argued for the imposition of at least a nominal penalty despite the Court’s decision to waive the fine.
 
Significance of the Ruling
 
This verdict reaffirms the judiciary’s commitment to uphold the right to reputation under Indian law while balancing it against freedom of speech. It underscores that public figures can seek legal protection against false and damaging allegations, especially when made with malice. Simultaneously, the Court showed leniency in procedural aspects like fines and probation, reflecting a nuanced approach towards punishment in defamation cases.
 
Case Details
• Case Number: SLP(Crl) No. 11953/2025
• Case Title: Medha Patkar v. VK Saxena
 
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