Pushpendra Baghel Granted Bail, Asset Liquidation Order

Case Name: Pushpendra Singh Baghel vs. State of Madhya Pradesh & Ors.
Petition: Writ Petition (CrL.) No(s). 125 of 2026 filed under Article 32 of the Constitution.
Court: Supreme Court of India, Criminal Original Jurisdiction.
Order Date: 29 May 2026.
Petitioner’s Custody: Continuous judicial custody since 27 June 2015 (over 11 years).
FIRs: Approximately 149 FIRs across ten states (Rajasthan, Madhya Pradesh, Uttar Pradesh, Maharashtra, Chhattisgarh, Gujarat, Haryana, Punjab, Uttarakhand, Himachal Pradesh).
Case Outcomes to Date: Around 40 matters concluded – 5‑6 acquittals and ~35 convictions; many trials pending.

Petitioner: Pushpendra Singh Baghel.
Respondents: State of Madhya Pradesh and other State Governments where FIRs are registered.
Regulatory Party: Securities and Exchange Board of India (SEBI) (impleaded as respondent per Interlocutory Application No. 166646 of 2026).
Companies Mentioned: Sai Prakash Properties Development Ltd (SPPDL), Sai Prakash Assurance Services Private Ltd, 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.
Counsel for Petitioner: Senior Counsel Vinay K. Garg.
Special Committee Chairperson: Former Chief Justice of Rajasthan and Madras High Courts, Justice Manindra Mohan Shrivastava.
Judges of the Bench: Justice Vikram Nath and Justice Sandeep Mehta.

Alleged operation of an unregistered Collective Investment Scheme (CIS) through SPPDL and associated entities, inviting public investments for land‑development projects with promises of high returns and profit sharing.
Issuance of Joint Venture Agreements, bonds, and documents purporting equity or proprietary interest in purchased lands; some investors were promised a doubling of their money within fixed periods.
Violation of SEBI Act, 1992 (Section 11AA) – registration and permission from SEBI were mandatory but not obtained.
Financial Mis‑representation: SEBI’s investigation revealed mobilisation of Rs 111,54,96,435 (≈ Rs 111.55 crore) from investors, whereas the company disclosed only ≈ Rs 84.76 crore.
Failure to disclose all bank accounts and continuation of fund collection after SEBI’s interim restraining order dated 26 December 2014.
Subsequent default on promised dividends/profits leading to FIRs under IPC Sections 420, 406, 409, 467, 468, 471, 120B, as well as offences under various State Chit Funds Acts, the Prize Chits and Money Circulation Schemes (Banning) Act, 1978, RBI Act, 1934, and state-specific Nikshepakon Acts.

The Court noted that the petitioner was a Director of SPPDL from 3 December 2009 to 14 June 2011, after which he resigned, filed Form‑32, and his shareholding reduced to zero.
The Court observed that the disputes are fundamentally monetary, involving investor claims that can be quantified and potentially settled through asset liquidation.
SEBI’s final order dated 29 July 2019 confirmed that SPPDL’s activities constituted an unregistered CIS in violation of SEBI regulations.
The Court recognized the multiplicity of criminal proceedings across jurisdictions and the petitioner’s prolonged incarceration, deeming a consolidated settlement in the interest of justice.

Interim Bail: Granted for three months, subject to furnishing two surety bonds of Rs 10,00,000 each and a personal bond of Rs 10,00,000 to the satisfaction of the Registrar (Judicial).
Special Committee Formation: Headed by Justice Manindra Mohan Shrivastava to identify investors, verify liabilities, and oversee liquidation of movable and immovable assets.
Asset Valuation: Cumulative marketable value of movable and immovable properties exceeds Rs 250 crore; outstanding investor liabilities are stated to be < Rs 115 crore.
Honorarium for Chairperson: Rs 50,00,000 (half payable upfront, half on submission of the first report).
Implementation: Registrar (Judicial) to issue release orders to all prisons; each State where FIRs or lands are located to appoint a Nodal Officer from the State administration.
SEBI’s Role: SEBI to cooperate fully, providing all relevant records, documents, and information to the Special Committee.

1. Details of all pending FIRs/criminal proceedings.

2. Investor details and claimed liabilities.

3. Complete particulars of all movable and immovable properties (including lands listed in the order).

4. Details of bank accounts, fixed deposits, and other liquid assets.

5. All title documents, revenue records, company records, and investor records.

6. Any additional material as requested by the Committee.

The petitioner will bear the expenses of the Special Committee for logistics and human resources.
The Committee may convene meetings in New Delhi, Jaipur, Bhopal, Rewa, Noida, or other appropriate locations.
Interim Status Report: To be submitted in sealed cover by 15 September 2026.
Next Hearing: Listed for 21 September 2026 to consider the Committee’s compliance/status report.

Interim bail granted for three months with stipulated surety bonds.
Formation of Special Committee chaired by Justice Manindra Mohan Shrivastava, empowered to identify investors, verify claims, and liquidate assets exceeding Rs 250 crore to settle liabilities < Rs 115 crore.
SEBI impleaded as a party respondent; required to cooperate and provide necessary information.
Registrar (Judicial) directed to ensure release orders are communicated to all relevant prisons and to provide contact details of the Committee’s Chairperson.
Each concerned State to appoint a Nodal Officer to facilitate the Committee’s work.
The Chairperson authorized an honorarium of Rs 50 lakh (half upfront).
The matter to be listed again on 21 September 2026 for review of the Committee’s interim report.