The Supreme Court granted regular bail to filmmaker Vikram Bhatt and Shwetambari Bhatt in a Rs 30 crore fraud case linked to Indira Entertainment LLP, set aside the Rajasthan High Court’s denial, and referred the dispute to mediation.
NEW DELHI: The Supreme Court has granted regular bail to filmmaker Vikram Bhatt and his wife, Shwetambari Bhatt, following their appeal against a Rajasthan High Court decision that had previously denied them relief.
The Court has also referred the parties to the Supreme Court Mediation Centre. This case originated from an FIR filed at the Bhupalpura Police Station in Udaipur, where the complainant, Dr. Ajay Murdia, accused the couple of orchestrating a fraud of approximately Rs 30 crore related to a four-film production agreement with Indira Entertainment LLP. Prior to this, the Court had granted interim bail to Shwetambari Bhatt.
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The Bench, comprising Chief Justice Surya Kant, Justice Joymalya Bagchi, and Justice Vipul M. Pancholi, stated,
“It seems to us that the dispute essentially pertains to a commercial transaction. Though the ingredients of committing offence for cheating etc. have been expressly mentioned in the FIR. Be that as it may, one of the appropriate recourses for the parties would be to make an endeavour to resolve the dispute adequately under the aegis of mediation… Since the Appellants are willing to join and cooperate with the ongoing investigation, we allow this appeal, set aside the interim order of the High Court, and without expressing any opinion on the merits, direct that Appellant No. 2 be also released. Both the appellants are granted regular bail.”
Factual Background:
Two bail applications under Section 483 of the B.N.S.S. (Bharatiya Nagarik Suraksha Sanhita) had been submitted on behalf of the Petitioners before the High Court against orders from the Lower Court, seeking regular bail in connection with First Information Report (FIR) No. 213/2025, Police Station Bhupalpura, District Udaipur, for offenses under Sections 316(2), 318(4), 336(3), 338, 340(2), and 61(2) of the Bharatiya Nyaya Sanhita (BNS).
The complainant, Dr. Ajay Murdia, alleged that an agreement was made through Dinesh Kataria, a resident of Udaipur, with Mumbai film producer Vikram Bhatt for the production of four films for Rs 47 crore. Subsequently, Indira Entertainment LLP was established, and the complainant paid over Rs 42.70 crore in multiple stages under the pretense of vendor payments. However, only one film was released, one was left unfinished, and the third was only about 25% complete, with shooting for the fourth yet to begin.
Despite this, Vikram Bhatt and Shwetambari Bhatt allegedly pressured the complainant for Rs 8.91 crore and later demanded an additional Rs 11 crore. When payment was not received, the production was halted, and they reportedly refused to return all assets related to the films, including raw footage, hard disks, music master files, costumes, scripts, and IPR. Furthermore, pressure was exerted on the complainant through the Federation by fabricating vendor claims worth Rs 2.46 crore.
In their defense, Senior Advocate VR Bajwa and Advocate Manvendra S. Bhati, representing Vikram P. Bhatt and Shwetambari V. Bhatt, argued that they were falsely implicated and had been in custody since December 7, 2025. They contended that two films had been completed, and work on the other two was stopped at the complainant’s request.
They added that the entire scam was perpetuated by the complainant’s accountant, Rakesh Panigrahi, for which FIR No. 803/2025 had been filed at the Versova Police Station in Mumbai. It was claimed that the complainant colluded to file this false case to evade responsibility. The High Court, after considering the evidence, the factual context, and other factors, declined to grant bail to the Petitioners at that time.
Arguments and Analysis of the Court:
The Court noted,
“The regular bail has been, however, granted with the expectation that the Appellants will act bona fide and try and will make efforts for amicable resolution of the commercial dispute.”
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Dave mentioned,
“Though the complainant himself has written to the first petitioner, who was released on bail the same day, saying that since you are released on bail, it’s time to finish our remaining commitment.”
In response, Singh stated,
“Actually, I’ll tell you… His company is in trouble. There is another FIR against him in Bombay doing exactly the same… After my FIR in Bombay, where he’s done exactly the same thing. His company is in difficulty. He’s actually asking for money because of his reputation, whatever his past reputation is… People are giving him money. And he is using that money for his own lot, for the company which is going into liquidation.”
Dave countered,
“My friend’s client wants the commitments to proceed, writes an email the next day, please do it… Nobody comes on the next day of release. Please fine, do this, complete the movies, etc. Four movies is the contract. Two are completed. The third is 70% complete. We are saying we’ll finish it… By being in custody, I cannot complete any movie of my Learned Friend.”
The court regarded the situation primarily as a commercial dispute, despite the accompanying criminal allegations. Given the appellants’ willingness to cooperate with the ongoing investigation, the High Court’s prior order denying relief was overturned. Bail was granted with the expectation that the parties would work in good faith to reach an amicable resolution to their financial disagreements.
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Senior Advocate Dave also informed the Court that the “majesty of the court” had been questioned in the Rajasthan Assembly, where discussions reportedly took place regarding the Court’s interim bail ruling in this case.
Dave stated,
“And after your Lordship passed this order of interim bail, a member of the assembly raised a question about how your Lordship could have granted interim bail. Is this the procedure? Because that person is connected to the Complainant. In the Rajasthan Assembly, a question was raised regarding how your Lordship could grant interim bail in this matter. It’s very surprising. We have the video, we have the assembly proceedings,”
CJI Kant responded,
“We know how to take strong action. Just because you belong to Rajasthan and have some influence there… If any of your machinery misadventures speak anything, we will transfer everything to Bombay in a minute… You cannot benefit from being a complainant. You are a pure person in Rajasthan. We would like to understand the warning. Nobody should be under the mistaken belief that because you can speak in the assembly, you are guilty. The law will take its own course. If anyone attempts to misbehave with the court…”
Senior Advocate Siddharth Dave represented the Petitioners, while Senior Advocate Vikas Singh appeared for the Respondents.
Case Title: Shwetambari Bhatt and Anr. v. State of Rajasthan SLP(Crl) 2647/2026
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