The Madhya Pradesh High Court has dismissed a plea by Dubai-based businessman Satish Sanpal, who gained public recognition from the Netflix show "Desi Bling", to quash an FIR accusing him of being the 'master mind' of an IPL betting racket. [2026 LiveLaw (MP) 326]

The bench of Justice Himanshu Joshi held,

"...upon consideration of the entire material available on record, this Court is of the considered view that the present case does not fall within any of the categories warranting exercise of inherent jurisdiction for quashing of the FIR or the consequential criminal proceedings. The contentions raised by the petitioner essentially relate to appreciation of evidence and the merits of the prosecution case, which cannot be adjudicated in the present proceedings. Consequently, no ground is made out for quashing FIR". 

Per the facts, the police received information about illegal IPL activities and conducted a raid at the residence of co-accused Sunil Thakur, wherein Sunil Thakur and Deepal Patel were found to be engaged in betting operations.

The police also found that the Sanpal was the mastermind of the alleged batting racket. The investigation revealed that he had opened fake shell companies in his own name and in the names of other people to conduct huge transactions and defraud the government. 

The counsel for Sanpal argued that the entire case is founded on suspicion and inadmissible statements recorded under Section 161 CrPC. The counsel argued that no material was collected in the investigation showing his active participation, conspiracy, or financial transaction. It was claimed that the alleged shell companies are genuine, filing their statutory returns, including ITRs and GST returns. 

It was argued that the directors of the said company, Laakshya, including Manoj Kumar Sanpal, on whose statement Sanpal was implicated, were themselves acquitted in connected proceedings involving similar allegations. 

It was further submitted that the alleged amount of ₹21 Lakhs was neither recovered from Sanpal nor at his instance. There was no material showing that Sanpal had committed any conscious act of printing, publishing, disseminating, or attempting to disseminate any digits, figures, signs, symbols, or pictures having nexus with the alleged gambling activity. 

The plea also referred to the High Court order of May 6, 2025, wherein the co-accused was granted relief by quashing proceedings arising from the same FIR.

The counsel for the State argued that the evidence collected during the investigation ought to be examined at the trial. It was argued that the order passed in favour of co-accused Sanjay Sanpal was rendered on the basis of particular facts and does not entitle Sanpal to similar relief. 

The court noted that under the inherent jurisdiction under Section 528 BNSS, it is not permitted to scrutinise the entire evidence meticulously and is only permitted to examine whether the evidence prima facie establishes the offence. 

The bench, examining the evidence, noted that the evidence indicates involvement of Sanpal in alleged betting activities. The bench further emphasized,

"Merely because the petitioner disputes the said material or offers an explanation in respect thereof cannot be a ground for quashing the criminal proceedings at this stage". 

Rejecting Sanpal's objection that he was not present in the country at the time of the offence, the bench noted that the proceedings claim his involvement through other persons, companies, and other means. 

The bench also rejected the objection that Sanpal was not named in the FIR or initial documents, highlighting,

"An FIR is not expected to contain the entire prosecution case or the names of every person who may ultimately be found involved in the commission of the offence. The investigating agency is entitled to investigate the source of the offence and the role of other persons who subsequently come to light during the investigation. The mere subsequent implication of the petitioner, therefore, cannot be treated as a ground for exercising the inherent jurisdiction of this Court". 

The bench further held that merely because the alleged amount of ₹21 Lakh was not recovered from Sanpal would not demolish the prosecution case at such a nascent stage, as it is not an indispensable requirement in every case of conspiracy. 

Additionally, the bench noted that the principle of parity is not an absolute rule and that relief is given based on peculiar facts attributable to the accused. 

"The fact that proceedings against one co-accused have been quashed on the basis of the material and circumstances prevailing in his case cannot, by itself, be treated as determinative of the case of the present petitioner. Unless the factual and evidentiary foundation of both cases is demonstrably identical, an order passed in favour of one accused cannot mechanically be extended to another accused". 

Therefore, the bench dismissed the petition, noting that no ground for quashing the FIR was made out. 

Interestingly, the High Court had refused to quash a cheating FIR against Hitesh Kumar Tarwani (co-accused), noting that his plea for parity cannot be applied mechanically when the evidence against the accused needs independent evaluation.

Case Title: Satish Sanpal v State of Madhya Pradesh, MCRC-11693-2026,

Citation: 2026 LiveLaw (MP) 326

For Petitioner: Senior Advocate Naman Nagrath with Advocate Anushasit Arya 

For State: Additional Advocate General BD Singh with Government Advocate Priyanka Mishra

Click here to read/download the Order