"So you mean to say that lawyers should not be prosecuted even if they commit fraud on the court?" Lawyers are no different. No matter who it is, if they commit fraud on court, they will be punished," the Court said.

In September 2020, the Supreme Court directed the Central Bureau of Investigation (CBI) to investigate a case involving a litigant who denied filing a special leave petition (SLP) in the apex court and claimed he never engaged the lawyers who purportedly represented him. 

The issue arose when petitioner Bhagwan Singh, more than a month after the Court had issued notice to the State of Uttar Pradesh in the disputed SLP, wrote to the Supreme Court Registry asserting that he had not initiated any such case. 

In response, the Court issued strict directives for advocates-on-record (AoRs), mandating that only lawyers authorised to argue a particular case on a specific day can mark their appearance. If there is any change in the name of the arguing advocate, the concerned AoR must promptly inform the court master either in advance or at the time of the hearing. 

During the hearing, a Bench of Justices Bela M. Trivedi and Satish Chandra Sharma reviewed the CBI's findings, which disclosed that a regular case was registered on November 22 against ten individuals accused of misusing court proceedings. 

The Supreme Court Bar Association (SCBA) and the Supreme Court Advocates-on-Record Association (SCAORA) jointly sought to modify the September 2020 order, arguing that it might adversely impact the rights of bar members. However, the Bench rejected their plea, along with a suggestion from Additional Solicitor General (ASG) Archana Dave that a warning could suffice as a remedy. 

"No warning. This statement doesn't suit on you. If any lawyer is playing fraud on the court, he or she will be punished," the Court said.

The Court observed that no further orders were required, as the CBI had already taken appropriate steps in the matter. Consequently, the Court closed the case.