This is a case-management order in a pending special leave petition; it decides nothing on the merits of the cheque-dishonour cases. Whether the dispute settles will turn on the mediation before Justice Najmi Waziri.
- Case
- Rajpal Naurang Yadav & Anr. v. M/s Murli Projects Pvt. Ltd. & Anr.
- Court
- Supreme Court of India
- Decision
- Bench
- Chief Justice Surya Kant; Joymalya Bagchi
- Case numbers
- SLP(Crl) Nos. 16923–16974/2026; Diary No. 48340/2026
- Outcome
- Case-management order dated 15 October 2026 in SLP(Crl) Nos. 16923–16974/2026: deposit recorded, mediation reference to Justice Najmi Waziri (retired Delhi High Court judge), passport release directed, matter to be posted after the mediation report.
Mediation after the Rs 2 crore deposit
On 15 October 2026, a Bench of Chief Justice Surya Kant and Justice Joymalya Bagchi of the Supreme Court referred the long-running cheque-dishonour dispute involving actor Rajpal Yadav and M/s Murli Projects Pvt. Ltd. to mediation, appointing Justice Najmi Waziri, a former judge of the Delhi High Court, as the sole mediator.
The order — uploaded on the Supreme Court's website on 21 October 2026 — records that the petitioners have now deposited a total of Rs 2 crore with the Court's Registry: Rs 1.15 crore by way of demand drafts in continuation of the Court's orders dated 8 September and 15 September 2026 (as modified on 7 October 2026), and a further Rs 85 lakh deposited on 13 October 2026 by the prospective buyer of the petitioners' ancestral property.
The dispute and how it reached the Supreme Court
The dispute stems from a 2010 financial agreement under which Yadav received Rs 5 crore from M/s Murli Projects Pvt. Ltd. to finance his directorial debut film, 'Ata Pata Laapata'. The complainant alleged that in 2013 Yadav tendered seven cheques of Rs 1.05 crore each towards settlement of the financial assistance, and that the cheques were dishonoured.
On 10 July 2026, the Delhi High Court upheld Yadav's conviction in the cheque-bounce cases and sentenced him to three months' imprisonment, while directing him to pay more than Rs 1 crore to the complainant in each of the seven complaints (adjusting around Rs 2 crore already paid) and ordering his wife Radha Rajpal Yadav to pay a fine of around Rs 5.5 lakh in each case.
Yadav's special leave petitions — SLP(Crl) Nos. 16923–16974/2026 — challenge the High Court's 10 July 2026 orders in a batch of criminal miscellaneous cases, criminal appeals and criminal revision petitions (including CRLMC No. 4870/2024 and CRLREVP Nos. 797–803/2024). On 8 September 2026 the Supreme Court issued notice on the petitions and exempted Yadav from surrendering subject to deposit; on 15 September it extended that exemption.
What the 15 October order directs
The Court said that owing to the issues briefly raised on behalf of the parties, the matter could be amicably resolved through mediation. Justice Najmi Waziri will act as the sole mediator; the parties are directed to contact him and fix a date for appearance, and he may ask them to appear in person or online and will fix his own fee in consultation with the parties.
The order also directs the trial court to release the passport of petitioner No. 1 (Rajpal Naurang Yadav), subject to such terms and conditions as the trial court may impose, so that he can continue with his professional pursuits. He may travel abroad only after complying with those terms and conditions, and must inform the trial court on his return.
The matter will be posted immediately after the mediation report is received.
BANTHRY ANALYSISWhat this order does not decide
Three limits matter. First, this is a case-management order in a pending special leave petition: the mediation reference, the deposit record and the passport direction decide nothing on the merits of the cheque-dishonour cases — Yadav's challenge to the conviction and three-month sentence remains pending.
Second, mediation is consensual: Justice Waziri can only resolve what the parties agree to; if settlement fails, the petitions return to the Court for adjudication.
Third, the passport release is conditional — the trial court sets the terms, and any travel abroad requires compliance with those terms first, with intimation to the trial court on return.
BANTHRY ANALYSISFor law students
This order illustrates how the Supreme Court manages high-profile criminal SLPs without deciding them. Note the sequencing: notice and exemption from surrender were made conditional on a substantial deposit (Rs 2 crore here) — a classic interim-bargaining device that protects the complainant's interest while keeping the petitioner's liberty intact during pendency.
Note also the Court's choice of remedy. In a criminal SLP arising from cheque-dishonour proceedings — a compoundable, essentially commercial dispute riding inside a criminal procedure — mediation is the natural fit: the underlying question is money, not public wrong. Contrast this with the YSRCP election order published the same day, where the Court gave the deciding authority (the Election Commission) a deadline and a floor, rather than deciding itself. Both orders show the same judicial habit: keep the merits untouched, but structure the process so the dispute can actually end.
One precision point for your notes: the record of proceedings does not record any reasons for the mediation reference beyond 'the issues briefly raised on behalf of the parties' and 'the complexity of the issues'. Do not attribute a fuller rationale to the Court than the order states.
READING PROMPTSQuestions for a closer reading
- Why did the Supreme Court consider mediation an appropriate course in these criminal special leave petitions, given that the underlying dispute is a cheque-dishonour matter?
- What three elements did the order combine — deposit, mediation and passport release — and what is the status of each if the mediation fails?
- The order says Yadav may travel abroad only after complying with the trial court's terms and must inform the trial court on return. Why does the Supreme Court route the passport release through the trial court rather than ordering it directly?
