Delhi High Court – Orders
Satish Sanpal vs Jagran Prakashan Limited & Ors on 6 May, 2026
$~41
* IN THE HIGH COURT OF DELHI AT NEW DELHI
+ CS(OS) 335/2026 and I.A. 10423/2026 and I.A. 10424/2026
SATISH SANPAL .....Plaintiff
Through: Mr. Sanjay Jain, Sr. Advocate, Mr.
Amit Sibal, Sr. Advocate with Mr. Ankur
Mahindro, Mr. Sarfharaj Ahmad, Mr. Nishant
Tripathi, Ms. Harshita Sukhija, Ms. Rishika
Agarwal, Ms. Priya Tyagi and Creesha Shastri,
Advocates.
versus
JAGRAN PRAKASHAN LIMITED & ORS. .....Defendants
Through: Mr. Birendra Kumar Mishra and Ms.
Alankrita Shukla, Ms. Poonam Atey, Advocates
for D1 and D2.
Mr. Akshay Goel, Advocate for D16.
Mr. Aditya Gupta and Mr. Rihith Venkatesan,
Advocates for D22.
Mr. Varun Pathak, Ms. Radhika Roy and Mr.
Bhavnish Kaur, Advocates for D23.
Mr. Abhishek Kumar Singh, Mr. Saurabh Kumar
and Mr. Saksham Chaturvedi, Advocates for D24.
Ms. Gauri Doburdhun, Sr. Panel Counsel with Mr.
Amit Kumar Rana, Govt. Pleader for D25 and
D26.
CORAM:
HON'BLE MR. JUSTICE VIKAS MAHAJAN
ORDER
% 06.05.2026
I.A. 12613/2026 ( under Section 151 CPC on behalf of Defendant no. 23,
seeking exemption from filing duly apostilled versions of its written
statements with affidavit of admission and denial, and reply to
plaintiffs’ interim application)
1. Allowed, subject to all just exceptions.
2. The application stands disposed of.
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I.A. 12612/2026 ( under Order XI rules 1(10) and 1(12) r/w Section 151
CPC on behalf of plaintiff, for filing additional documents)
3. Allowed, subject to all just exceptions.
4. The application stands disposed of.
I.A. 10424/2026 ( under Section 151 CPC on behalf of plaintiff, seeking
exemption from serving notice u/s 80 CPC, to defendant nos. 25 & 26)
5. This is an application filed by the plaintiff under section 80 CPC,
seeking exemption from serving notice to defendant nos. 25 and 26 on the
ground that urgent interim relief is sought in the instant suit.
6. Notably, no urgent relief has been sought or being granted against
defendant nos. 25 and 26. However, this Court is inclined to grant urgent
interim relief to the plaintiff qua other defendants, therefore, this application
is allowed.
7. The application stands disposed of.
CS (OS) 335/2026
8. The plaint be registered as suit.
9. Issue summons to the defendants. Mr. Birendra Kumar Mishra,
learned counsel appearing on behalf of defendant nos. 1 and 2; Mr. Akshay
Goel, learned counsel appearing on behalf of defendant no. 16; Mr. Aditya
Gupta, learned counsel appearing on behalf of defendant no. 22; Mr. Varun
Pathak, learned counsel appearing on behalf of defendant no. 23; Mr.
Abhishek Kumar Singh, learned counsel appearing on behalf of defendant
no. 24 and Ms. Gauri Doburdhun, learned counsel appearing on behalf of
defendant nos. 25 and 26, accept summons and waive formal service of
summons.
10. They submit that copy of the plaint, I.A.s and documents have been
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received by them.
11. On plaintiff taking steps, summons be issued to defendant nos. 3 to 15
and 17 to 21 by all permissible modes.
12. The summons shall indicate that written statement must be filed
within thirty days from the date of receipt of summons.
13. The defendants shall also file an affidavit of admission/denial of the
documents filed by the plaintiff, failing which the written statement shall not
be taken on record.
14. The plaintiff is at liberty to file replication thereto within thirty days
after filing of the written statement. The replication shall be accompanied by
affidavit of admission/denial in respect of the documents filed by the
defendants, failing which the replication shall not be taken on record.
15. It is made clear that any unjustified denial of documents may lead to
an order of costs against the concerned party.
16. Any party seeking inspection of documents may do so in accordance
with the Delhi High Court (Original Side) Rules, 2018.
17. List before the learned Joint Registrar for completion of service,
pleadings, admission/denial of documents and marking of exhibits on
21.08.2026.
18. List before Court thereafter on a date to be assigned by the learned
Joint Registrar.
I.A. 10423/2026 ( under Order XXXIX rules 1 and 2 r/w Section 151
CPC on behalf of plaintiff, seeking ad interim ex-parte injunction
against the defendants)
19. This is an application filed by the plaintiff seeking grant of ad interim
ex parte injunction.
20. Issue notice. Learned counsels for defendant nos. 1 and 2, 16 and 22
to 26 accept notice.
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21. On plaintiff taking steps, notice be issued to defendant nos. 3 to 15
and 17 to 21 by all permissible modes.
22. The plaintiff has filed the present suit inter alia praying for decree of
permanent injunction and damages.
23. The case set out in the plaint is that the plaintiff is a Dubai-based
entrepreneur and the Chairman of ANAX Holding, a diversified business
group operating in real estate, hospitality, and investment management. The
plaintiff claims to be a globally renowned professional and philanthropist
with an impeccable reputation, having been recognized by international
publications such as Forbes Middle East and honoured with the Golden
Excellency Award, among other accolades.
24. The defendant nos. 1 to 21 comprise content originators, publishers,
digital news portals, and journalists. The other defendants include
intermediary digital platforms, namely YouTube/Google LLC (defendant
no. 22), Meta Platforms, Inc./Instagram (defendant no. 23), and LinkedIn
(defendant no. 24). Defendant nos. 25 and 26 are the Ministry of Electronics
and Information Technology (MEITY) and the Department of
Telecommunications (DoT), respectively.
25. It is stated that commencing from approximately 2014, and escalating
dramatically between 2022 and 2025, a coordinated and malicious campaign
of defamation has been initiated against the plaintiff across multiple digital
platforms, social media networks, and news portals. It is alleged that the
defendants have repeatedly and falsely fabricated a narrative portraying the
plaintiff as a ‘hawala operator’, ‘bookie (satoria)’, ‘mastermind of criminal
syndicates’, and an ‘absconding fugitive’.
26. It is stated that the impugned publications do not merely report
allegations or police investigations but prematurely pronounce guilt in a
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declaratory and conclusive manner. The plaintiff asserts that he has been
granted bail by competent courts in the criminal proceedings referenced in
the offending articles, and has never been convicted or declared a
proclaimed offender by any court of competent jurisdiction in India.
27. Mr. Amit Sibal, learned Senior Counsel appearing on behalf of the
plaintiff vehemently argues that the defamatory posts, videos, and articles
published by the defendants have blatantly transgressed the contours of
journalistic reportage and amount to a media trial.
28. He submits that the defendants have systematically and repeatedly
labelled the plaintiff as a ‘hawala operator’, ‘fraudster’, ‘Satta King’, and an
‘absconding fugitive’ in a declaratory and conclusive manner.
29. He emphasizes the fact that the plaintiff has been granted bail by
competent courts in all the three criminal proceedings referenced in the
impugned publications. That apart, he has already been granted bail in eight
out of the nine criminal cases registered against him. Furthermore, in the
remaining criminal case the plaintiff is accused of a bailable offence and is
in the process of securing bail in that case as well.
30. He further contends that the plaintiff has not been declared a
proclaimed offender by any competent court, therefore, branding the
plaintiff as an ‘absconder’ or a convicted criminal is demonstrably false and
malicious.
31. He further submits that the publications are the product of a targeted
and orchestrated campaign designed to exploit the plaintiff’s popularity for
commercial gain and click-bait. He points out that the defendants have
presented unverified police allegations as absolute facts, without conducting
any independent fact-checking or journalistic due diligence.
32. To substantiate his contention, he draws the attention of the Court to
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three bail orders which are annexed as document nos. 24 to 26 with the
plaint. He submits that the aforementioned three bail orders are in reference
to the FIRs which have been primarily mentioned by the defendants in the
impugned defamatory articles.
33. He contends that certain defendants are relying on older articles from
2022, 2023, and 2025 that contain false allegations against the plaintiff. This
has created a ripple effect, where past publications are continuously recycled
to unfairly tarnish the plaintiff’s image while the formal investigations are
still pending. Further, he also submits that the plaintiff has been suffering
damages owing to the continuous publications and hence, has approached
the Hon’ble Court praying for injunction.
34. Mr. Sibal expounds on the immediate, tangible, and irreparable harm
suffered by the plaintiff due to this concerted campaign. He draws the
Court’s attention to specific instances demonstrating this harm:
a. The Government of St. Lucia explicitly cited the adverse ‘research’
and media reports concerning the plaintiff’s alleged involvement in
money laundering and gambling to deny citizenship to the plaintiff’s
brother, thereby causing harm to the plaintiff’s family as well.
b. Financial institutions have severely restricted the plaintiff’s banking
operations. Notably, ENBD Bank directed the transfer/withdrawal of
funds and closure of accounts citing non-compliance with their
current criteria, seemingly on account of defamatory campaign
against the plaintiff.
c. Third-party financial service providers, such as PEMO.IO, suspended
the plaintiff’s accounts following inquiries into the adverse media
reports, forcing the plaintiff to disrupt automated workflows and incur
additional operational costs.
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35. Lastly, he submits that the plaintiff issued comprehensive Cease and
Desist notices to the defendants on various dates in February, March, and
April 2026, explicitly informing them of the plaintiff’s bail status and the
falsity of the ‘absconder’ tag. Despite receiving actual notice of the falsity of
their claims, the defendants have not taken down the defamatory content or
published a retraction. Mr. Sibal argues that this deliberate silence and
continued publication constitutes actual malice, entirely disentitling the
defendants to any defence of good faith, and making out a strong prima
facie case for the grant of an ex-parte ad-interim injunction.
36. Per contra, Mr. Varun Pathak, learned counsel appearing for
defendant no. 23 contends that the plaintiff’s request for global blocking of
contested content should be denied as the issue concerning validity of global
injunctions is sub judice before a Division Bench of this Hon’ble Court.
37. Mr. Sibal, on instructions, submits that at this stage he does not wish
to press the takedown of the content on the platform of defendant nos. 22
and 23.
38. I have heard the counsels for the parties and also perused the material
on record.
39. In the context of the present case, when the FIRs already stand
registered against the plaintiff and bail has been granted to him in the said
FIRs, but the investigation is still underway, the defendants may be within
their right to share or disseminate the contents of FIR or material which is
informative but in public interest. However, at the same time the defendants
have to exercise restraint and refrain from publishing and circulating any
material referring to the character of the plaintiff which creates an
atmosphere of prejudice for him or mar his reputation and thereby causes
prejudice to an ongoing investigation.
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40. This approach is warranted to finely balance the competing
constitutional rights i.e. the defendants’ right of freedom to speech and
expression under Article 19(1)(a) and the plaintiff’s right to reputation and a
fair trial guaranteed under Article 21 of the Constitution of India. The
guiding principles in this regard have been articulated by the Division Bench
of Bombay High Court in Nilesh Navalakha and Ors. v. Union of India
and Ors. 2021 SCC OnLine Bom 56, while examining the impact of trial by
media on pending investigation. The relevant excerpts from the said decision
reads thus:
“353. While not proposing to issue directions for postponement of
news reporting for the reasons noted above, yet, bearing in mind
the adverse impact that a trial by media could have on pending
investigations (which was not the subject matter of consideration
before the Supreme Court in the aforesaid decisions), that an
accused is entitled to Constitutional protections and invasion of
his rights is to be zealously guarded, that there is an emerging
need to foster a degree of responsibility as well as promote
accountability and the reason in the paragraph that follows, we
do not consider it to be either impermissible or imprudent in the
present context to maintain a fine balance between competing
rights as well as having regard to the ever-changing societal
needs to suggest measures for exercise of restraint by the media
in respect of certain specified matters, with a view to secure
proper administration of justice, while it proceeds to exercise its
right to report.
XXXX XXXX XXXX XXXX
355. Having given our anxious consideration to all aspects of the
matter, we are inclined to the opinion that the press/media ought to
avoid/regulate certain reports/discussions/debates/interviews in
respect of and/or touching upon any on-going inquiry/investigation
into a criminal offence and that only those items are presented for
reading/viewing and otherwise perceiving through the senses
which are merely informative but in public interest instead of what,
according to the media, the public is interested in. No
report/discussion/debate/interview should be presented by the
press/media which could harm the interests of the accused beingThis is a digitally signed order.
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investigated or a witness in the case or any such person who may
be relevant for any investigation, with a view to satiate the thirst
of stealing a march over competitors in the field of reporting.
Accordingly, we direct the press/media to exercise restraint and
refrain from printing/displaying any news item and/or initiating
any discussion/debate/interview of the nature, as indicated
hereunder:
a. In relation to death by suicide, depicting the deceased as one
having a weak character or intruding in any manner on the
privacy of the deceased;
b. That causes prejudice to an ongoing inquiry/investigation by:
(i) Referring to the character of the accused/victim and
creating an atmosphere of prejudice for both;
(ii) Holding interviews with the victim, the witnesses and/or any
of their family members and displaying it on screen;
(iii) Analyzing versions of witnesses, whose evidence could be
vital at the stage of trial;
(iv) Publishing a confession allegedly made to a police officer
by an accused and trying to make the public believe that the
same is a piece of evidence which is admissible before a Court
and there is no reason for the Court not to act upon it, without
letting the public know the nitty-gritty of the Evidence Act,
1872;
(v) Printing photographs of an accused and thereby
facilitating his identification;
(vi) Criticizing the investigative agency based on half-baked
information without proper research;
(vii) Pronouncing on the merits of the case, including pre-
judging the guilt or innocence qua an accused or an
individual not yet wanted in a case, as the case may be;
(viii) Recreating/reconstructing a crime scene and depicting
how the accused committed the crime;
(ix) Predicting the proposed/future course of action including
steps that ought to be taken in a particular direction to
complete the investigation; and
(x) Leaking sensitive and confidential information from
materials collected by the investigating agency;
c. Acting in any manner so as to violate the provisions of the
Programme Code as prescribed under section 5 of the CTVN Act
read with rule 6 of the CTVN Rules and thereby inviting contempt
of court; and
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d. Indulging in character assassination of any individual and
thereby mar his reputation.
XXXX XXXX XXXX XXXX
358. At the same time, while emphasizing on the need for a free,
fair, effective and meaningful investigation of an FIR disclosing
commission of cognizable offence by an accused be it a celebrity
or an ordinary person to be conducted by the investigative
agency, we also consider it appropriate to remind the
investigative agencies that they are entitled to maintain secrecy in
course of investigation and are under no obligation to divulge
materials thus collected. If indeed there is leakage or disclosure of
materials, which has the potential of stifling a proper
investigation, it could pave the way for such information being laid
before the competent court having powers to punish for criminal
contempt under section 2(c) of the CoC Act and in an appropriate
case, for being dealt with in accordance with law.”
(emphasis supplied)
41. A comparative analysis of the First Information Reports (FIRs) and
the impugned publications reveals a clear dichotomy. A bare perusal of the
FIRs placed on record, specifically FIR No. 271/2022 (Omti Police Station),
FIR No. 170/2022 (Madan Mahal Police Station), and FIR No. 356/2022
(Lardganj Police Station) indicates that the police are investigating
allegations pertaining to the operation of betting (satta) networks, the
recovery of cash, and the alleged unauthorized use of identity documents
(Aadhaar/PAN) to open bank accounts for transactions. The said allegations
are, however, subject to investigation and eventual judicial scrutiny.
42. In stark contrast, the narrative propagated by the media houses and
digital platforms, comprising Defendant Nos. 1 to 21 and disseminated
across various platforms as detailed in paragraph 63 of the plaint, has gone
beyond the realm of the FIRs. The publications do not merely report the
allegations contained in the police complaints; rather, they prematurely
adjudicate the matter. For instance:
a. Pre-judging Guilt: Defendants such as Jai Lok/defendant no. 6;
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Naidunia/defendant no. 2; Umesh Gujarathi/defendant no. 5; and D.B.
Corp/defendant no. 9 have repeatedly used declaratory language,
labeling the plaintiff as a, ‘Satoriya’, ‘fraudster’, ‘faraar’ and ‘India’s
wanted criminal’.
b. Financial Exaggerations: The articles make definitive claims that the
plaintiff has laundered Rs. 1,000 crores through 13 bogus/shell
companies using hawala channels, and connect him to the Mahadev
online betting app scandal, allegations that find no mention in the
referenced FIRs or any judicial determination.
c. Targeting Plaintiff’s Enterprise: The publications actively target the
plaintiff’s Dubai-based business conglomerate, ANAX Holding,
falsely projecting to the global community that his entire $3 billion
business valuation may stem from criminal sources. Platforms like
Pattyfriedmann.com/defendant no. 15 and
Cybercriminal.com/defendant no. 12 explicitly warn prospective
investors and partners to avoid engaging with ANAX entities, thereby
causing direct commercial disparagement.
43. Furthermore, the labelling of the plaintiff as an ‘absconder’,
‘fugitive’, and ‘farar’ is premature. The material on record indicates that the
plaintiff has already been granted bail by competent courts vide bail orders
dated 10.12.2025, 13.01.2026 and 21.01.2026 (annexed as Document nos.
24, 25 and 26 respectively, with the plaint) in the criminal proceedings
referenced in the impugned publications. Incidentally, none of the impugned
articles refer to any judicial order whereby the plaintiff has been declared a
Proclaimed Offender by any court. The continued tagging of the plaintiff as
an ‘absconder’, especially after the receipt of various Cease and Desist
notices dated 19.02.2026, 24.02.2026, 06.03.2026, 25.03.2026, 01.04.2026,
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03.04.2026 etc., informing the defendants of the bail orders, prima facie
points towards malice.
44. By labelling and implying the plaintiff to be a culprit, the defendants
have arrogated to themselves the adjudicatory function of the competent
courts. Such pronouncements grossly violate the foundational principle of
criminal jurisprudence, namely, the presumption of innocence until proven
guilty.
45. Prima facie, what is particularly unsettling for the plainitff is the
cascading effect resulting from the impugned articles. A perusal of the
documents placed on record reveals that the majority of the foundational
defamatory articles date back to the years 2022, 2023, and 2025. Recent
articles are actively recycling and hyper-linking these unverified older
publications to create a facade of investigative credibility to the fresh
defamatory publications. For instance, Defendant No. 8/Legal Observer,
Defendant No. 14/Hannahhowell, Defendant No. 12/CyberCriminal, , and
Defendant No. 15/Pattyfriedmann, in their recent articles published on
15.12.2025, 31.10.2025, 15.12.2025 and 15.02.2026, respectively,
prominently rely upon hyper-links of older articles whereby outdated and
unverified accusations have been brought to fore, which prima facie has the
potential of tarnishing the plaintiff’s image while formal investigations are
still ongoing.
46. In this day and age of digital/social media, digital defamation carries
real, tangible, and instant legal and commercial consequences. The plaintiff
has placed on record material illustrating this immediate and irreparable
injury, viz:
(i) the Government of St. Lucia explicitly cited these adverse media
reports regarding money laundering to deny citizenship to theThis is a digitally signed order.
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plaintiff’s brother, causing profound familial prejudice.
(ii) the global financial institution and service provider, such as
PEMO.IO, has imposed severe restrictions, suspending the plaintiff’s
accounts, and severed business ties with the plaintiff’s entities.
47. At this juncture, reference may also be had to the decision of the
coordinate bench of this Court in Vinai Kumar Saxena v.Aam Aadmi Party
(2022) 5 HCC (Del) 662, wherein it was observed as under:
“25. On behalf of the defendants, it has also been vehemently
contended that in cases of defamation, so long as some material
has been placed on record, the veracity of the allegations can only
be tested in trial and the adequate remedy would be damages, not
interim injunction. I do not agree with the said submission. In
appropriate cases where the court is of the view that statements
are unsubstantiated and have been made in a reckless manner
without regard to the truth, in order to cause injury to the
reputation of the plaintiff, the court would be justified in
granting an interim injunction. If the aforesaid submission of the
defendants is accepted, it would give the defendant a free reign to
continue making defamatory statements against the plaintiff and
continue to tarnish his reputation. Therefore, the court cannot be
powerless in such a situation. After suffering the brunt of such
defamatory content, it is difficult to contemplate a complete
restitution through damages. Such cases demand immediate
injunctive relief and the court cannot wait for the defendants to
place their response on record.”
(emphasis supplied)
48. Likewise, apt would be to refer to a decision of Hon’ble Supreme
Court in Subramanian Swamy v. Union of India (2016) 7 SCC 221,
wherein it was held as under:
“144……………………..We are in respectful agreement with the
aforesaid enunciation of law. Reputation being an inherent
component of Article 21, we do not think it should be allowed to
be sullied solely because another individual can have its freedom.
It is not a restriction that has an inevitable consequence which
impairs circulation of thought and ideas. In fact, it is controlThis is a digitally signed order.
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regard being had to another person’s right to go to Court and state
that he has been wronged and abused. He can take recourse to a
procedure recognized and accepted in law to retrieve and redeem
his reputation. Therefore, the balance between the two rights
needs to be struck. “Reputation” of one cannot be allowed to be
crucified at the altar of the other’s right of free speech……………
XXXX XXXX XXXX XXXX
195. One cannot be unmindful that right to freedom of speech
and expression is a highly valued and cherished right but the
Constitution conceives of reasonable
restriction…………………Right to free speech cannot mean that a
citizen can defame the other. Protection of reputation is a
fundamental right. It is also a human right. Cumulatively it
serves the social interest……………………………………………”
(emphasis supplied)
49. Having noticed the aforesaid dicta as well as the material on record,
this Court is of the prima facie view that the allegations in the articles
published by the defendants have prematurely labelled the plaintiff as the
culprit, branding him a ‘fraudster’, ‘Satta King’, and an ‘absconder’, even
when the criminal investigations are underway and the plaintiff has already
been granted bail by competent courts. Further, it also prima facie appears
that some of the impugned articles go beyond the realm of the contents of
the FIRs, thereby potentially harming the reputation of the plaintiff, who is
now facing severe tangible consequences, including the denial of citizenship
to his brother by the Government of St. Lucia and the abrupt suspension of
his corporate account by financial institution PEMO.IO, despite his
established commercial standing of several years, as claimed.
50. This Court is satisfied that the plaintiff will suffer an irreparable loss
and injury in case an ad interim order of injunction in favour of the plaintiff
is not granted. The balance of convenience is also in favour of an interim
order of status quo being passed.
51. Under the circumstances, it is deemed appropriate to direct defendant
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nos. 1 to 21 not to publish any post making identical or similar defamatory
allegations against the plaintiff, till the next date of hearing. Ordered
accordingly. Further, the plaintiff has produced a tabulated chart of the links
and the defendants who have uploaded them in para 63 of the plaint.
Accordingly, the aforesaid defendants, as featured in the tabulated chart in
para 63 of the plaint, are directed to forthwith take down/remove the
defamatory posts published by them or on their platforms, and maintain that
position, till the next date of hearing.
52. Provisions of Order XXXIX Rule 3 CPC be complied with by the
plaintiff qua defendant nos. 3 to 15 and 17 to 21, within a period of three
weeks from today and affidavit of compliance be filed within a period of one
week thereafter.
53. Let reply to the application be filed within a period of 04 weeks.
54. Rejoinder thereto, if any, be filed within a period of two weeks
thereafter.
55. List before the learned Joint Registrar for completion of service and
pleadings on 21.08.2026.
VIKAS MAHAJAN, J
MAY 6, 2026/jg
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