'No Evidence, Mechanical Summoning': Allahabad HC Quashes Defamation Case Against Jaipur Dialogues, Sanjay Dixit

The Allahabad High Court recently quashed criminal defamation proceedings initiated against former IAS officer and Jaipur Dialogues founder Sanjay Dixit, holding that the complaint failed to satisfy the essential statutory requirement of reputational harm under Section 499 of the Indian Penal Code.

The bench of Justice Brij Raj Singh, allowing Dixit’s petition under Section 482 of the Code of Criminal Procedure, set aside the summoning order issued by a Lucknow magistrate and quashed the entire complaint case filed by Syed Rizwan Ahmad in 2020. Court found that the magistrate had proceeded mechanically without examining whether the alleged imputations had, in fact, lowered the complainant’s reputation in the estimation of others, a mandatory condition under Explanation 4 to Section 499 IPC.

The criminal complaint stemmed from a tweet posted by Dixit in July 2019 and a YouTube programme aired in October 2020 on the Jaipur Dialogues platform. In the programme, allegations were aired against Ahmad based on statements made by a woman who claimed harassment. Ahmad alleged that the content was defamatory and damaged his reputation, prompting him to initiate criminal proceedings under Section 500 IPC.

Dixit approached the High Court contending that the complaint did not disclose any offence of defamation in law. His counsel argued that the complainant neither pleaded nor proved that his reputation had been lowered in the eyes of society. It was further submitted that no witness was examined under Section 202 CrPC, despite Dixit residing outside the territorial jurisdiction of the magistrate, rendering the summoning order legally unsustainable.

The High Court closely examined the statutory framework governing criminal defamation and reiterated that Explanation 4 to Section 499 IPC operates as an inbuilt safeguard. Court noted that an imputation amounts to defamation only if it lowers the moral or intellectual character of a person, or their credit or standing, in the estimation of others. Mere subjective grievance or personal perception of harm, court held, is insufficient.

Significantly, court observed that Ahmad had not produced even a single witness to establish that the alleged imputations had harmed his reputation in public perception. The magistrate, however, proceeded to issue summons based solely on the complainant’s statement under Section 200 CrPC, without undertaking the limited but mandatory inquiry contemplated under Section 202.

Relying on a consistent line of Supreme Court and High Court precedents, court held that the absence of such inquiry amounted to a procedural irregularity going to the root of the matter. Court emphasised that criminal defamation proceedings, given their chilling effect on speech, require strict scrutiny at the threshold stage.

Court also noted that while the complainant claimed that the allegedly defamatory content was widely viewed on social media, no material or testimony was brought on record to demonstrate reputational damage as understood in law. The High Court clarified that reputational harm must be assessed objectively and through evidence, not presumed merely because content was published or disseminated online.

Rejecting the complainant’s argument that procedural defects were curable at trial, court held that the failure to satisfy the foundational ingredients of defamation could not be overlooked. It concluded that allowing the proceedings to continue would amount to an abuse of the process of court.

Accordingly, the High Court quashed the summoning order dated December 15, 2022, and the entire criminal proceedings pending before the additional chief judicial magistrate (Custom), Lucknow. No order as to costs was passed. 

Case Title: Sanjay Dixit vs. State of U.P. Thru. Addl. Chief Secy. Home Deptt. Lko. and another

Order Date: January 13, 2026

Bench: Justice Brij Raj Singh