Filing ₹250 Security Deposit On Same Day As Presentation Of Revision Plea Suffices Municipality (Election Petition) Rules: MP High Court

The Madhya Pradesh High Court has held that the security deposit of ₹250 required under Rule 19 (2) of the MP Municipality Election Petition Rules can be filed on the same day as the presentation of a revision at the filing window. In doing so, the court clarified that this would be sufficient compliance with Rule 19 and would not lead to the dismissal of the revision.

The bench of Justice Deepak Khot observed;

"If petitioner has deposited the amount of security, as required under Rule 19 of the Rules of 1962, simultaneously with the presentation of the case at the filing window and the same has been submitted with memo of petition during filing, this Court finds that it is sufficient compliance of Rule 19 of Rules 1962".

The revisionist, Shankar Prasad Gupta, filed a revision petition challenging an order of October 7, 2025, passed by the District Judge of Sidhi in an election matter. The respondent, Lovkesh Singh, objected to the maintainability of the revision, arguing that the revisionist had not deposited the mandatory security deposit of ₹250 'at the time of presentation' of the petition as required under Rule 19(2) of the 1962 Rules.

The revisionist, however, had deposited the amount on the same day, and it was deposited after the case number was generated.

The court examined the procedural steps involved in filing cases under the MP High Court Rules, 2008, particularly Chapter 11, which governs the filing, scrutiny, and registration of petitions.

The court noted that the petition in question contained the receipt of deposit as part of its annexures and that the checker's report, prepared on October 9, 2025, confirmed that the petition was properly drawn, duly stamped, and accompanied by the necessary documents.

In the present case, it was noted that the revisionist had presented the petition at the window of the filing section and simultaneously applied to the Registrar General for the deposit of the said security deposit of ₹250 as per the Rules of 1962.

"This Court has no reason to doubt that such deposit has been made simultaneously with presentation of the petition at the window of filing section after generation of case number. But, because of that only, it cannot be inferred that as soon as such memo of petition is presented at the window of filing section, it completes the presentation", the court added.

Furthermore, the bench noted that if the revisionist has deposited the required amount of security as per Rule 19 of the 1962 Rules, simultaneously with the presentation of the case at the filing window and submitted with a memo of petition, then this constitutes sufficient compliance with Rule 19 of the 1962 Rules.

The court observed that it is a usual practice that when any case is filed, the formalities regarding to amount of court fees or other security deposit are done simultaneously at the time of presentation.

Therefore, the court held that the same has been done in the present case, and therefore rejected the contentions raised by the respondents.

Case Title: Shankar Prasad Gupta v Lovkesh Singh [2025:MPHC-JBP:52815]

Citation: 2025 LiveLaw (MP) 241

For Revisionist: Senior Advocate Prakash Upadhyay with Advocate Joyveer Singh Saini

For Respondents: Senior Advocate Ravish Chandra Agarwal with Advocate Himanshu Tiwari

For Respondent on Caveat: Advocate Suyash Mohan Guru

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