The Karnataka High Court rejected a PIL seeking directions to Rahul Gandhi and others to disclose a supposed “Volume 2” of Mahatma Gandhi’s autobiography. The bench termed the plea “vague” and said no such relief could be granted.
Bengaluru: On August 28, 2025, the Karnataka High Court dismissed a Public Interest Litigation (PIL) that had been filed against Leader of Opposition Rahul Gandhi, Lok Sabha Speaker Om Birla, and others.
The PIL was brought by an organization named Jagrutha Karnataka, Jagrutha Bharatha, represented by its President K N Manjunatha.
The petition mainly sought directions to Rahul Gandhi and others to disclose an alleged “Volume 2” of Mahatma Gandhi’s autobiography My Experiments with Truth, which the petitioner claimed would cover the years 1926 to 1947.
Manjunatha told the court that while studying British-era history and modern Indian history, he discovered what he called “significant distortions and gaps”.
He alleged that these gaps had resulted in “political turmoil in the country.”
He further claimed that key incidents from the freedom struggle and even the Partition of India were missing in official narratives and school textbooks.
Based on this argument, he alleged the existence of an “additional volume of Gandhi’s autobiography” that had not been made public and demanded its disclosure.
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The PIL did not stop there. It also asked the High Court to issue an
“interim direction to produce a photograph of Mahatma Gandhi participating in the Indian Independence celebrations on August 15, 1947”
to confirm whether the petitioner’s claims about missing records were true.
However, the petition did not find favour with the court. The matter was heard by a division bench of Chief Justice Vibhu Bakhru and Justice CM Joshi, which dismissed the plea outright.
The judges observed that the PIL’s demands were “vague” and made it clear that “no such relief could be granted.” The bench also clarified that the petitioner was free to pursue historical research on his own.
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Interestingly, during the hearing, the Court refrained from making any observations on the role of Rahul Gandhi, Om Birla, or Kapil Sibal, despite the petitioner specifically naming them in his PIL.
Instead, the Bench kept its focus limited to the maintainability of the petition itself, underlining that PILs cannot be used to compel political leaders or constitutional authorities to answer speculative historical questions.
Legal commentators noted that this approach is consistent with past rulings of the Supreme Court and High Courts, where similar petitions rooted in “academic debates” have been dismissed at the admission stage itself.
The order stated that
“if the petitioner wished to undertake scholarly research into history, there were no legal impediments to doing so.”
With these remarks, the court dismissed the PIL against Rahul Gandhi and others, closing the door on the demand for the so-called missing second volume of Gandhi’s autobiography and the request for a 1947 Independence Day photograph.
Case Title:
Jagrutha Karnataka Jagrutha Bharatha vs The Secretary & Others
Case No.: WP 33695/2025
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