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Representing a Person After Accusing Him in PILs? MP High Court Says BCI Should Examine Advocate’s Conduct

Representing a Person After Accusing Him in PILs? MP High Court Says BCI Should Examine Advocate’s Conduct

Anil Singh v. State of MP, Decided on 16.07.2026

Madhya Pradesh High Court

The Madhya Pradesh High Court has dismissed three public interest litigations (PILs) filed by an Advocate while observing that the Bar Council of India (BCI) should examine whether his conduct in subsequently representing a person against whom he had made allegations in the PILs amounts to professional misconduct. The Court also imposed costs of ₹25,000 in each petition.

A Division Bench comprising Acting Chief Justice Vivek Rusia and Justice Pradeep Mittal was hearing three PILs challenging the appointments of officials of the Madhya Pradesh Private University Regulatory Commission and alleging misuse of office, public funds and corruption. The petitioner, appearing in person, sought inquiries by authorities including the Lokayukta and CBI into the alleged irregularities.

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The Court noted that before approaching it, the petitioner had already submitted detailed complaints to the Lokayukta, and by the time the petitions were heard, those complaints had been disposed of. In such circumstances, the Bench held that the PILs were not liable to be entertained.

During the hearing, the State informed the Court that the petitioner had subsequently appeared as counsel in two writ petitions challenging recovery proceedings, despite having impleaded him as a respondent and levelled allegations against him in the present PILs. The petitioner acknowledged that those writ petitions had been filed after the PILs.

Taking note of the sequence of events, the Bench observed that once the petitioner had made allegations against the respondent in the PILs, he ought not to have accepted his brief as counsel in subsequent proceedings. The Court remarked that it was for the Bar Council of India to inquire whether such conduct falls within the ambit of professional misconduct.

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The Court further observed that there was a possibility that the information forming the basis of the PILs had been obtained against the respondent, who later became the petitioner’s client, and that this fact had allegedly been suppressed in the petitions. It also noted that some of the respondents had already completed their tenure and that new Chairperson and Members of the Regulatory Commission had been appointed in November 2025.

Finding no merit in the petitions, the Division Bench dismissed all three writ petitions and directed the petitioner to pay ₹25,000 as costs in each case.

Appearances

Petitioner: Shri Anil Singh, appeared in person.

For the State: Dr. S. S. Chouhan, Government Advocate.

For Respondents No. 4, 5, 6 & 8: Shri Anvesh Shrivastava, Advocate.

For Respondent No. 7: Shri Aman Pandey, Advocate.

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Anil Singh v. State of MP

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