TANKADHAR TRIPATHYversusDIPALI DAS

                [2025] 8 S.C.R. 1137 : 2025 INSC 1017

                             Tankadhar Tripathy
                                     v.
                                 Dipali Das
                       (Civil Appeal No. 11017 of 2025)
                                 22 August 2025
              [Surya Kant* and Joymalya Bagchi, JJ.]


                            Issue for Consideration
       Whether non-compliance with the proviso to Section 83(1)(c) of the
       Representation of the People Act, 1951 is a fatal defect, rendering
       the Election Petition non-maintainable at the threshold.

                                   Headnotes†
       Representation of the People Act, 1951 – s.83(1)(c) – Conduct
       of Elections Rules, 1961 – Rule 94-A – Code of Civil Procedure,
       1908 – Or. VII, r.11 – Whether the requirement of filing an
       affidavit under the proviso to s.83(1)(c) of the RP Act is of a
       mandatory character:
       Held: This Court has underscored that the requirement of filing an
       affidavit under the proviso to s.83(1)(c) of the RP Act is not of a
       mandatory character, and that ‘substantial compliance’ therewith
       would suffice – Where an affidavit is already on record, albeit not
       in the prescribed Form 25, the proper course would be to afford
       the Election Petitioner an opportunity to file a corrected affidavit in
       conformity with the prescribed form – On facts, there are apparent
       deficiencies in the Impugned Order, namely, (i) to specify the
       extent of compliance with the High Court Rules; (ii) to enumerate
       the defects necessitating rectification; and (iii) to examine whether
       the principles of substantial compliance have been followed or
       not – This Court deems it appropriate to remit the case to the High
       Court with a request to answer these questions and re-determine
       whether these were curable defects which could be permitted to
       be rectified. [Paras 17, 23]

       Representation of the People Act, 1951 – s.80-A – High Court
       Rules – Chapter XXXIII – Rules, 7, 21:
       Held: It becomes clear from a perusal of these Rules (Rules 7
       and 21) that at the stage of presenting an Election Petition, it

* Author
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    must be examined by the prescribed officer of the High Court,
    alongwith its accompanying documents, so as to ensure that the
    same conforms with the requirements of law and the applicable
    rules – During this process, if it is found that the Election Petition or
    its accompanying documents suffer from any defects or omissions,
    the same shall be placed before the learned Judge-cum-Election
    Tribunal – The judicial proceedings thereafter shall be conducted in
    accordance with the rules and procedures described in Rule 21 –
    Such procedure also contemplates compliance with the contents
    and format of an affidavit elaborately described in Chapter VI of
    the High Court Rules – In the instant case, the impugned order
    does not clarify whether the above-stated process of scrutiny was
    duly followed by the prescribed officer at the time of presentation
    of the Election Petition. [Paras 20, 21]

    Representation of the People Act, 1951 – s.83(1)(c) – Obligation
    on the Election Petitioner:
    Held: The law evolved in the recent decisions of this Court,
    places an obligation on the Election Petitioner to file an affidavit
    which amounts to ‘substantial compliance’ with the prescribed
    format – Whether an affidavit appended with an Election Petition
    has ‘substantially complied’ with or ‘omitted’ to do so is essentially
    a question of fact to be determined by juxtaposing the allegations
    of ‘corrupt practices’ averred in the Election Petition vis-à-vis the
    contents of the supporting affidavit – Substantial compliance in
    ordinary terms means, almost, actual compliance with the essence
    of the enactment, or perhaps, in simpler terms, to do all that is
    reasonably expected, which satisfies the substance of the Statute –
    It, however, cannot be inferred to mean mere lip service to the
    requirements of the law – That being so, although the High Court
    has concluded that the affidavit ‘substantially complied’ with the
    proviso to s.83(1)(c), it has not detailed the examination conducted
    in order to reach such a conclusion. [Para 22]

                               Case Law Cited
    Ravinder Singh v. Janmeja Singh and Others [2000] Supp. 3 SCR
    331 : (2000) 8 SCC 191; G. M. Siddeshwar v. Prasanna Kumar
    [2013] 4 SCR 1107 : (2013) 4 SCC 776; A. Manju v. Prajwal
    Revanna [2021] 12 SCR 195 : (2022) 3 SCC 269; Thangjam
    Arunkumar v. Yumkham Erabot Singh [2023] 11 SCR 392 : (2023)
    17 SCC 500 – referred to.
[2025] 8 S.C.R.                                                             1139

                     Tankadhar Tripathy v. Dipali Das


                                List of Acts
     Representation of the People Act, 1951; Conduct of Elections
     Rules, 1961; High Court Rules; Code of Civil Procedure, 1908.

                             List of Keywords
     Election Petition; Obligation on the Election Petitioner; Requirement
     of filing an affidavit; Substantial compliance; Corrected affidavit;
     Form 25 Affidavit.

                            Case Arising From
     CIVIL APPELLATE JURISDICTION: Civil Appeal No. 11017 of 2025
     From the Judgment and Order dated 21.03.2025 of the High Court
     of Orissa at Cuttack in IA No. 111 of 2024

                         Appearances for Parties
     Advs. for the Appellant:
     Maninder Singh, Gopal Agarwal, Sr. Advs., Ms. Mithu Jain, Kunal
     Rana, Shashwat Jaiswal, Milind Rai, Amarpal Singh Dua.
     Advs. for the Respondent:
     Dr. Abhishek Manu Singhvi, Gaurav Agrawal, K Parameshwar,
     Sr. Advs.,Tarani Kanta Biswal, C. George Thomas, Ansh Mittal,
     Gurkaranbir Singh.

                Judgment / Order of the Supreme Court

                                 Judgment

     Surya Kant, J.

     Leave granted.
2.   The instant appeal revolves around certain procedural and technical
     requisites, generally ancillary to the filing of election petitions, which
     are mandated in Section 83 of the Representation of the People
     Act, 1951 (RP Act). In particular, this matter pertains to the degree
     of ‘substantial compliance’ with the prescribed Form 25 affidavit, as
     encapsulated in the proviso to Section 83(1)(c) of the RP Act read
     with Rule 94-A of the Conduct of Elections Rules, 1961.
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     A.   Facts
3.   Before we foray into analysing the legal aspects involved in dissecting
     the Appellant’s claim, it is incumbent upon us to briefly chronicle the
     factual background giving rise to the instant appeal.
4.   The Governor of the State of Odisha issued a notification on
     26.04.2024 to hold General Elections to constitute a new State
     Assembly. The election schedule was released, and both the
     Appellant and the Respondent filed their nominations from the
     07-Jharsuguda Assembly Constituency. The polling took place on
     20.05.2024, followed by the counting on 04.06.2024. The Appellant
     was eventually declared elected as the returned candidate by a
     margin of 1,333 votes.
5.   The Respondent, having gotten the second highest votes, filed
     ELPET No. 7 of 2024 (Election Petition) before the High Court
     of Orissa at Cuttack (High Court), seeking the Appellant’s election
     to be declared void and set aside. The Respondent in her Election
     Petition urged two distinct grounds of challenge: (i) that the Appellant
     failed to make a complete and truthful disclosure of his assets,
     liabilities, and criminal antecedents, and further omitted to publish
     particulars of such criminal antecedents in a newspaper having
     wide circulation, thereby indulging in ‘corrupt practices’ as defined in
     Section 123 of the RP Act; and (ii) that there existed discrepancies
     in the Control Unit Identification Numbers of the Electronic Voting
     Machines (EVMs), which allegedly rendered 6,313 votes as void.
     It was thus contended that, since the number of such votes far
     exceeded the margin of victory, the result of the election stood
     materially affected.
6.   The Appellant, in turn, objected to the maintainability of the Election
     Petition on the sheet anchor of Order VII Rule 11 of the Code of Civil
     Procedure, 1908 (CPC), praying for its rejection at the very threshold.
     Pursuantly, the Appellant urged the following grounds: (i) non-joinder
     of necessary parties, including a third candidate who had contested the
     election; (ii) Vague, evasive, and vexatious averments in the Election
     Petition; and (iii) non-compliance with the mandatory requirement of
     filing the affidavit in Form 25, as prescribed in the proviso to Section
     83(1)(c) of the RP Act. The Appellant urged that these defects were
     fatal to the maintainability of the Election Petition. In the alternative,
     the Appellant sought an order under Order VI Rule 16 of the CPC,
[2025] 8 S.C.R.                                                          1141

                     Tankadhar Tripathy v. Dipali Das


     to strike out the portions of the pleadings mainly pertaining to the
     allegations of ‘corrupt practices’ contained in the Election Petition.
7.   Upon consideration of the competing claims, the High Court, vide its
     order dated 21.03.2025 (Impugned Order), dismissed the Appellant’s
     application(s) and granted the Respondent three weeks’ time to
     file an affidavit in the prescribed Form 25. The High Court opined
     that: (i) it was not mandatory to file a separate or second affidavit,
     specifically in relation to the allegations of ‘corrupt practices,’ along
     with the Election Petition; (ii) the solitary affidavit filed and verified,
     substantially fulfilled the requirement contemplated under the proviso
     to Section 83(1)(c) of the RP Act, and therefore the Election Petition
     could not be rejected solely on this ground; (iii) in any event, any
     deficiency in the Form 25 affidavit could be cured by affording the
     Election Petitioner an opportunity to file a separate affidavit; and (iv)
     the Election Petition disclosed specific allegations containing material
     facts accompanied by the requisite particulars. In view thereof, the
     High Court concluded that the matter raised triable issues and did
     not merit rejection at the outset.
8.   Aggrieved, the Appellant has approached this Court.

     B.    Contentions of the Parties
9.   Mr. Maninder Singh, Learned Senior Counsel appearing for the
     Appellant, while assailing the decision of the High Court, advanced
     the following submissions:
     a.    The allegations set out in the Election Petition were vague,
           unnecessary, frivolous, scandalous, and vexatious. The petition
           disclosed no cause of action for its maintainability under any of
           the grounds enumerated in Section 100 of the RP Act, inasmuch
           as the Respondent failed to furnish particulars of the polling
           agents in respect of the 43 polling stations where the alleged
           discrepancies are claimed to have occurred. Furthermore,
           the precise nature of such discrepancies was not specified,
           whether concerning the entries made, the counting of votes,
           or omissions in completing Form 17C, etc. Additionally, no
           documents were annexed to substantiate the allegations so
           made. These deficiencies, cumulatively, constituted substantial
           non-compliance with Section 83 of the RP Act and, therefore,
           warranted rejection of the Election Petition at the first instance.
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    b.   The allegations regarding corrupt practices—specifically, the
         alleged failure of the Appellant to disclose all his criminal
         antecedents together with his assets and liabilities—were
         wholly devoid of the necessary particulars, such as the date
         of the alleged offence, the persons involved, and the source
         of information. The mere pleading of material facts, without the
         accompanying particulars, rendered the Election Petition liable
         to be rejected under Order VII Rule 11 of the CPC, read with
         Section 86 of the RP Act.
    c.   In the alternative, such incomplete and vague pleadings ought
         to have been struck out under Order VI Rule 16 of the CPC. In
         any event, the Appellant asserted that he had no knowledge of
         the said criminal cases at the time of filing his nomination papers,
         and that the details furnished in Form 26 were in accordance
         with the letter dated 15.04.2024 issued by the Superintendent
         of Police. Hence, there was no wilful suppression of information
         regarding his criminal antecedents.
    d.   The Respondent did not raise any objection before the
         Returning Officer with respect to the alleged non-disclosure
         of the Appellant’s criminal antecedents or his assets and
         liabilities at the stage when the nomination papers were filed
         and scrutinised. Consequently, the Respondent was precluded
         from raising such allegations at a belated stage as a means to
         assail and overturn the result of a fair and transparent election.
    e.   Each page of the Election Petition was not signed and verified by
         the Oath Commissioner and the Respondent, as required under
         Section 83(1)(c) of the RP Act read with Order VI Rule 15 of the
         CPC. This defect was detrimental to the case and, consequently,
         the Election Petition ought to have been rejected in limine.
    f.   Finally, the Election Petition was not accompanied by a separate
         affidavit in Form 25, as mandated by the proviso to Section 83(1)
         (c) of the RP Act. The filing of such an affidavit was mandatory
         when allegations of corrupt practices were made out, and the
         omission to do so warranted dismissal of the petition at the
         very threshold.
10. Per contra, Dr. Abhishekh Manu Singhvi and Mr. Gaurav Agrawal,
    Learned Senior Counsel appearing on behalf of the Respondent,
    put forth the following submissions:
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                     Tankadhar Tripathy v. Dipali Das


     a.    As per Section 86 of the RP Act, an Election Petition could be
           dismissed only for non-compliance with Sections 81, 82, or 171
           of the RP Act. Permitting the dismissal of an Election Petition
           for non-compliance with Section 83 of the RP Act, a section
           not enumerated in Section 86, would be against the statutory
           mandate and legislative intent behind the RP Act.
     b.    The Election Petition contained specific allegations, duly
           accompanied by the necessary particulars, in relation to the
           alleged corrupt practices as well as the discrepancies in the
           EVMs. In support thereof, the Respondent furnished details
           including the case numbers, the names of the concerned police
           stations, particulars of the First Information Reports, and a
           comparative table indicating the votes recorded vis-à-vis the
           votes counted. It was urged that the pleadings in the Election
           Petition provided the Appellant with adequate particulars of the
           allegations to enable the preparation of his defence, and that,
           having regard to the nature of such allegations, their veracity
           could be determined only in the course of trial.
     c.    A list of documents intended to substantiate the material facts
           was duly disclosed by the Respondent after the ‘prayer clause’
           and before the ‘verification’ commenced. In terms of Chapter
           XXXIII, Rule 10 of the Rules of the High Court of Orissa, 1948
           (High Court Rules), the Respondent was under no obligation
           to file such documents as annexures at the time of presenting
           the Election Petition. The production of the same was required
           only upon a date being fixed for that purpose by the concerned
           Learned Judge.
     d.    Finally, any defect in the verification of the Election Petition
           or in the format of the affidavit filed in Form 25 would not, in
           itself, be fatal to the proceedings. Such defects, if any, are, as
           repeatedly held by this Court, curable in nature, and the High
           Court followed the proper course by affording the Election
           Petitioner an opportunity to rectify the same.
11. It is relevant to note at this juncture that when this appeal first came
    up for hearing before this Court on 13.05.2025, we suggested to the
    parties to put up their respective proposals regarding the deletion
    of certain parts of the pleadings so as to streamline and trim the
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     issues under consideration. Pursuant to such suggestion, both sides
     submitted their respective proposals to this Court. On consideration
     of these proposals, we find that the parties are ad idem atleast on
     the issue of deletion of their respective pleadings so far as the same
     pertain to a third candidate.

     C.     Issues
12. In view of this, the only issue that survives for consideration is as
    follows:
     (i)    Whether non-compliance with the proviso to Section 83(1)(c)
            of the RP Act is a fatal defect, rendering the Election Petition
            non-maintainable at the threshold?

     D.     Analysis
13. In furtherance of his claim, the Appellant urged that the affidavit
    accompanying the Election Petition in support of the allegations of
    ‘corrupt practices’ was defective as it was not filed in the prescribed
    format of Form 25. The Appellant also claimed that such a defect
    was detrimental to the maintainability of the Election Petition and
    thus, it ought to have been rejected at the very threshold. Reliance
    was placed, in this regard, upon the decision of this Court in
    Ravinder Singh v. Janmeja Singh and Others, 1 where, in
    paragraph 11, it was observed that Section 83 of the RP Act was
    mandatory in nature, and that an Election Petition containing
    allegations of corrupt practices must, in law, be accompanied by
    an affidavit to that effect in the prescribed form. It was further
    held that the absence of a proper affidavit, filed in support of such
    allegations, constituted a fatal defect warranting immediate dismissal
    of the election petition.
14. To the contrary, the Respondent submitted that no such separate
    affidavit was required to accompany an Election Petition alleging
    the conduct of ‘corrupt practices.’ The Respondent, in fact, went
    so far as to claim that even the complete absence of an affidavit
    in Form 25 was curable and the concerned court should always
    grant time to the Election Petitioner to rectify such defects before
    proceeding to trial.


1   (2000) 8 SCC 191.
[2025] 8 S.C.R.                                                        1145

                         Tankadhar Tripathy v. Dipali Das


15. After the decision in Ravinder Singh (supra), the question concerning
    non-compliance with the proviso to Section 83(1)(c) of the RP Act and
    its effect on the maintainability of an election petition was reconsidered
    by a 3-Judge Bench of this Court in G. M. Siddeshwar v. Prasanna
    Kumar.2 In that case, this Court held that while non-compliance with
    the provisions of Section 83 of the RP Act was curable, there must
    nonetheless be ‘substantial compliance’ therewith.
16. It was clarified that in cases of total and complete non-compliance
    with Section 83, the pleading could not be regarded as an Election
    Petition and was liable to be rejected at the outset. Proceeding on
    this premise, the Court further held that although a defective affidavit
    may not, by itself, render an Election Petition non-maintainable,
    the High Court must ensure that the defect was cured prior to the
    commencement of trial so as to enable the returned candidate to
    effectively meet the allegations and not be taken by surprise at that
    stage. This decision thus reflects a more liberal approach towards
    the substance of a Form 25 affidavit, as contrasted with the stricter
    view adopted in Ravinder Singh (supra).
17. This ‘evolved’ view of the law has since been relied upon and followed
    by this Court in more recent judgements, such as A. Manju v. Prajwal
    Revanna3 and Thangjam Arunkumar v. Yumkham Erabot Singh.4
    In these decisions, this Court has further underscored that the
    requirement of filing an affidavit under the proviso to Section 83(1)(c)
    of the RP Act is not of a mandatory character, and that ‘substantial
    compliance’ therewith would suffice. Indeed, where an affidavit is
    already on record, albeit not in the prescribed Form 25, the proper
    course would be to afford the Election Petitioner an opportunity to
    file a corrected affidavit in conformity with the prescribed form.
18. In our considered view, the question of law on this aspect is extremely
    well-settled in the above-cited cases, and thus the issue raised
    is no longer res integra. However, one question that still requires
    consideration, in terms of G. M. Siddeshwar (supra), is: whether the
    defects in a Form 25 affidavit filed alongside the Election Petition are
    required to be cured by way of a fresh affidavit within the stipulated


2   (2013) 4 SCC 776.
3   (2022) 3 SCC 269.
4   (2023) 17 SCC 500.
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     period of limitation or whether it can be filed at any point during the
     proceedings, even after such period has expired?
19. In this respect, the first port of call ought to be the ‘Rules to Regulate
    Proceedings under Section 80-A of the Representation of the People
    Act, 1951 (Act 43 of 1951),’ which are contained in Chapter XXXIII
    of the High Court Rules. Rules 7 and 21 of this Chapter prescribe
    the process of scrutiny of an Election Petition and the procedure to
    be followed while conducting the proceedings. Rules 7 and 21 read
    as follows:
           “7. Every election petition shall, on presentation, be
           examined by the Stamp Reporter, who shall certify thereon
           whether the petition is in conformity with the requirements of
           law and the rules applicable to the same and the petition
           with the defects or omissions if any, as reported by
           the Stamp Reporter, shall be referred to the Judge
           who has been assigned by the Chief Justice for the
           trial of the Election Petition for orders under section
           86 of the Act.
           21. Subject to the provisions of the Act and these rules,
           the provisions of Code of Civil Procedure, so far as may
           be applicable, will apply to the proceedings arising under
           the Act. The rules regarding applications and affidavits
           in Chapter VI Part II of the Orissa High Court Rules
           Vol. I shall apply mutatis mutandis to the applications
           under this Chapter.”
                                                  [Emphasis supplied]

20. It becomes clear from a perusal of these Rules that at the stage of
    presenting an Election Petition, it must be examined by the prescribed
    officer of the High Court, alongwith its accompanying documents,
    so as to ensure that the same conforms with the requirements of
    law and the applicable rules. During this process, if it is found that
    the Election Petition or its accompanying documents suffer from any
    defects or omissions, the same shall be placed before the learned
    Judge-cum-Election Tribunal. The judicial proceedings thereafter shall
    be conducted in accordance with the rules and procedures described
    in Rule 21 above. Such procedure also contemplates compliance
    with the contents and format of an affidavit elaborately described in
    Chapter VI of the High Court Rules.
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                     Tankadhar Tripathy v. Dipali Das


21. In the instant case, the Impugned Order does not clarify whether the
    above-stated process of scrutiny was duly followed by the prescribed
    officer at the time of presentation of the Election Petition. Further,
    there is no reference to whether any defects were noticed at the
    time of admission. In the same vein, it is also indiscernible from the
    Impugned Order whether the Learned Judge, to whom the Election
    Petition was assigned, granted any time to the Election Petitioner to
    cure such defects at the first instance. Instead, the Impugned Order,
    which emanated from an adjudication at the Order VII Rule 11 stage,
    simply granted the Respondent an opportunity to “cure defects” and
    further provided a period of three weeks to do so. The Impugned
    Order thus neither sheds any light on the nature of the defects so
    recognized, nor clarifies whether the opportunity to rectify such defects
    was accorded before or after the expiry of the period of limitation.
22. Alongside this, it is pertinent to note that the law evolved in the
    recent decisions of this Court, as cited in paragraphs 15 to 17 above,
    places an obligation on the Election Petitioner to file an affidavit
    which amounts to ‘substantial compliance’ with the prescribed
    format. Whether an affidavit appended with an Election Petition
    has ‘substantially complied’ with or ‘omitted’ to do so is essentially
    a question of fact to be determined by juxtaposing the allegations
    of ‘corrupt practices’ averred in the Election Petition vis-à-vis the
    contents of the supporting affidavit. Substantial compliance in
    ordinary terms means, almost, actual compliance with the essence
    of the enactment, or perhaps, in simpler terms, to do all that is
    reasonably expected, which satisfies the substance of the Statute.
    It, however, cannot be inferred to mean mere lip service to the
    requirements of the law. That being so, although the High Court has
    concluded that the affidavit ‘substantially complied’ with the proviso to
    Section 83(1)(c), it has not detailed the examination conducted in
    order to reach such a conclusion. As a result, the necessary facts-
    based analysis appears to have escaped attention.
23. In view of these apparent deficiencies in the Impugned Order, namely,
    (i) to specify the extent of compliance with the High Court Rules;
    (ii) to enumerate the defects necessitating rectification; and (iii) to
    examine whether the principles of substantial compliance have been
    followed or not, we deem it appropriate to remit the case to the High
    Court with a request to answer these questions and re-determine
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     whether these were curable defects which could be permitted to be
     rectified. We are inclined to remand the matter also for the reason
     that the High Court has correctly identified some grounds, other than
     ‘corrupt practices,’ on which the Election Petition deserves further
     consideration on merits.

     E.   Conclusion and Directions
24. In light of the above discussion, the matter stands remitted to the
    High Court with the following directions and conclusions:
     a.   The High Court is requested to identify and enumerate the
          defects in the Form 25 affidavit and assess whether such
          defects, if any, were curable. To this end, the High Court may
          consider the following as preliminary issues:
          i.     Whether the affidavit in the instant case, alleging ‘corrupt
                 practices,’ is defective and does not satisfy the requirement
                 under Form 25?
          ii.    If defective, does it substantially satisfy the requirements
                 of Form 25, and can it be so construed in accordance
                 with the decisions of this Court cited in paragraphs 15 to
                 17 above?
          iii.   If the defect in the Form 25 affidavit could be cured, would
                 it be mandatory to file a supplementary affidavit within the
                 period of limitation?
          iv.    Whether the High Court-cum-Election Tribunal possesses
                 the power to condone the delay and permit the Election
                 Petitioner to file the affidavit, in the prescribed format of
                 Form 25, beyond the period of limitation?
     b.   Additionally, we allow the proposals submitted by the parties and
          request the High Court to strike out the portions of the pleadings
          that they have mutually agreed to expunge from the record.
     c.   Upon striking out of such pleadings, the High Court shall afford
          the parties reasonable time to carry out the consequential
          amendments to the Election Petition and the Written Statement(s).
          Thereafter, the High Court may proceed to frame issues on the
          merits of the matter.
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                       Tankadhar Tripathy v. Dipali Das


25. The instant appeal stands disposed of in these terms.
26. Ordered accordingly. Pending applications, if any, are also to be
    disposed of in the above terms.

     Result of the case: Matter remitted to High Court.




     †
         Headnotes prepared by: Ankit Gyan