Case Name: Pushpendra Singh Baghel vs. State of Madhya Pradesh & Ors.
Petition: Writ Petition (CrL.) No(s). 125 of 2026.
Court: Supreme Court of India, Criminal Original Jurisdiction.
Order Date: 29 May 2026.
Alleged Violation Period: Activities giving rise to FIRs from 2015 through 2024, with the scheme allegedly operated before the petitioner’s resignation in June 2011.
Parties Involved
Petitioner: Pushpendra Singh Baghel.
Respondents: State of Madhya Pradesh and other State Governments where FIRs were lodged.
Companies/Entities: Sai Prakash Properties Development Ltd (SPPDL) and its sister concerns – Sai Prakash Assurance Services Private Limited, Sai Prakash Financial Advisory Services, Sai Prakash Endurance Pvt. Ltd., Bind Finance Ltd., Linc Financial Services Pvt. Ltd., Sai Prakash Organic Food Ltd., Sai Prakash Power India Ltd., Sai Prakash Telecommunications Ltd., Sai Jyoti Machinery Pvt. Ltd., Sai Prakash Resosys Pvt. Ltd., Sai Prakash Developers India Ltd., Rural Industry Development Institute, Naina Telesystems Pvt. Ltd., Lakshraj Conveyors Pvt. Ltd., Chambal Malwa Multi Credit Cooperative Society.
Regulator: Securities and Exchange Board of India (SEBI) (impleaded as party respondent).
Special Committee Chairperson: Former Chief Justice of Rajasthan and Madras High Courts, Manindra Mohan Shrivastava.
Issues / Allegations / Violations
Alleged operation of an unregistered Collective Investment Scheme (CIS) through SPPDL, inviting public investments for land‑development projects with promises of high returns and doubling of capital.
Failure to obtain mandatory registration under Section 11AA of the SEBI Act.
Mobilisation of Rs 111.54 crore from investors, while the company disclosed only Rs 84.76 crore.
Continuation of fund collection after SEBI’s interim restraining order dated 26 December 2014.
Default on promised dividends/profits, leading to FIRs under IPC Sections 420, 406, 409, 467, 468, 471, 120B, as well as violations of various Chit Funds Acts, the Prize Chits and Money Circulation Schemes (Banning) Act, 1978, RBI Act, 1934, and state Nikshepakon Acts.
Approximately 149 FIRs across ten states; about 35 convictions, 5‑6 acquittals.
Petitioner’s claim of having been a director of SPPDL only from 3 Dec 2009 to 14 Jun 2011 and having zero shareholding thereafter.
Findings & Observations
SEBI’s investigation concluded that SPPDL’s activities constituted an unregistered CIS in violation of SEBI regulations.
The Court noted the multiplicity of criminal proceedings and the petitioner’s continuous incarceration for over 11 years.
Petitioner expressed willingness to settle with investors by liquidating movable and immovable assets listed in the affidavit dated 25 May 2026.
The aggregate marketable value of the assets is claimed to exceed Rs 250 crore, while outstanding liabilities to investors are stated to be less than Rs 115 crore.
Penalties / Settlements / Directions
Interim Bail: Granted for three months, subject to two surety bonds of Rs 10 lakh each and a personal bond of the same amount.
Special Committee: Constituted, headed by Justice Manindra Mohan Shrivastava, to identify investors, verify liabilities, and oversee liquidation of assets.
Asset Liquidation: Committee to sell lands and movable assets (valued > Rs 250 crore) to settle investor claims (< Rs 115 crore).
Committee Honorarium: Rs 50 lakh, payable half upfront and half upon first report submission.
Petitioner’s Obligations: Provide comprehensive details of all pending FIRs, investor lists, asset particulars, bank accounts, title documents, and any other material requested by the Committee.
State Cooperation: Each concerned State to appoint a Nodal Officer; Chief Secretaries to facilitate the Committee’s work.
SEBI: Impleaded as a party; directed to cooperate fully and furnish all relevant records.
Corrective Actions & Future Obligations
Petitioner to bear all expenses of the Special Committee.
Committee to submit an interim status report in sealed cover by 15 September 2026 outlining progress on investor identification, liability verification, and asset valuation/liquidation.
Further hearing scheduled for 21 September 2026 to consider the Committee’s compliance/status report.
Registrar (Judicial) to ensure release orders are communicated to all prisons/courts where the petitioner is detained.
Final Ruling & Enforcement
Interim bail granted with stipulated sureties.
Formation of Special Committee with defined mandate and honorarium.
SEBI notified as a respondent and required to assist.
Detailed compliance framework laid down for asset liquidation and settlement of investor claims, aiming to consolidate and resolve the multitude of criminal proceedings across jurisdictions.