There are disputes that are merely commercial. There are disputes that are merely reputational. And then there are disputes in which the integrity of documents placed before a court itself becomes the central issue.

The proceeding involving Krishan Rattan and Ankiti Bose has now moved into the third category—at least at the allegation and procedural stage.

On 24 September 2026, Defendant No. 1 in Krishan Rattan v. Nitin Naresh & Ors., CS(OS) No. 815/2026, filed an application invoking Section 379 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS). The application does not itself constitute a conviction or a finding of perjury. It asks the Delhi High Court to conduct a preliminary inquiry into whether the plaint and its supporting affidavits, verification, Vakalatnama, urgent application and electronic-evidence certificate were altered, reused or presented in circumstances that could attract offences relating to false evidence and fabrication of evidence. The application identifies Sections 227, 228, 229, 236 and 237 of the Bharatiya Nyaya Sanhita, 2023 (BNS) among the provisions potentially attracted.

That distinction is crucial.

The question before the Court is not presently “Is Krishan Rattan guilty of perjury?” The question is whether the documentary trail is sufficiently troubling to justify a judicial inquiry.

And the application attempts to make that question unavoidable by putting two alleged versions of the same litigation record side by side.

The Section 379 application: what exactly is being alleged?

Section 379 BNSS is not itself the substantive offence of perjury. It is the statutory procedure for cases falling within Section 215, allowing a court, where it considers an inquiry expedient in the interests of justice, to conduct a preliminary inquiry, record a finding and make a written complaint to a Magistrate.

Section 215, in turn, restricts cognizance of specified offences affecting the administration of justice—including offences corresponding to false evidence and false declarations committed in or in relation to court proceedings—except on a written complaint from the concerned court or authorised judicial officer. That is why an application under Section 379 can become the procedural gateway in a case alleging perjury in court proceedings.

The distinction matters because the application is essentially asking the High Court:

Do the documents on the record justify moving from a private allegation to a court-supervised inquiry?

That is a substantially more serious question than an ordinary pleading dispute.

The Supreme Court has repeatedly emphasised that perjury-related proceedings should not become automatic weapons in every litigation. In Chajoo Ram v. Radhey Shyam, the Court stressed deliberate and conscious falsehood on a matter of substance; in Amarsang Nathaji v. Hardik Harshadbhai Patel, it emphasised both a prima facie foundation and the expediency of an inquiry in the interests of justice. The same body of law recognises that the administration of justice—not simply the private interests of the litigants—is the reason the court takes exceptional action.

That is precisely the hurdle the present application is attempting to cross.

1. Version A versus Version B: the central documentary controversy

The most striking allegation is deceptively simple.

According to the application, the Plaintiff’s plaint was signed and supported by documents dated 1 September 2026. A first version—described as “Version A”—was served upon the defendants on 8 September 2026. A second version—“Version B”—was served on 10 September 2026.

The application says Version B was materially different from Version A even though the same supporting affidavit, verification and Section 63 BSA certificate dated 1 September were carried forward.

The applicant expressly says that the objection is not that a litigant can never improve a draft before filing. The sharper argument is that once factual and substantive portions of a pleading are changed, the supporting declaration of truth cannot simply be assumed to authenticate facts that allegedly did not exist when the declaration was sworn.

That is where the case becomes uncomfortable.

The dispute is no longer merely “there was an amended draft”.

It becomes:

What exactly was sworn? What exactly was changed? When was it changed? Who changed it? And what document was ultimately placed before the Court under the authority of that earlier oath?

2. One affidavit, two different factual narratives?

The application identifies an especially concrete example.

In one version of paragraph 2, the text allegedly stated that the defendant had communicated with the Plaintiff “and her legal representatives by email.”

In the later version, the alleged wording changes the description of the communication and introduces communication through a customer-service portal and email, while removing the reference to legal representatives. The Section 379 application argues that both versions cannot simultaneously describe precisely the same factual event and yet both be covered by an affidavit sworn on 1 September to the deponent’s own knowledge.

This is one of the most important allegations in the entire application because it goes directly to the evidentiary function of verification.

The Supreme Court has long treated verification as more than bureaucratic decoration. In A.K.K. Nambiar v. Union of India, the Court explained that verification serves to identify what is asserted from personal knowledge and what is based on information, while also making the deponent responsible for the assertions. The Court has subsequently reiterated the importance of properly verified affidavits.

That makes the alleged chronology highly significant:

1 September: affidavit and verification.

8 September: Version A allegedly served.

10 September: Version B allegedly served.

The application asks the obvious question: if a material factual proposition appears in Version B but not Version A, how could the 1 September affidavit have personally verified that proposition?

That is not a typo-sized question.

3. The “Suit Property” that allegedly appeared in a defamation suit

Perhaps the most eye-catching allegation concerns the urgent application.

The Version A material reproduced in the application contains the statement:

“restoration of possession of the Suit Property”

Yet the underlying proceeding is described as a defamation action concerning publications on Inventiva, with claims for declaration, injunctions and ₹2 crore damages. The Section 379 application points out that the defamation pleadings do not plead a “Suit Property” or seek restoration of possession.

The disputed urgent application is dated 1 September 2026. The defendant’s application says Version A contained the plaintiff’s signature, while the later Version B allegedly removed the disputed “Suit Property” wording and also removed the plaintiff’s signature while retaining the 1 September date.

The allegation is therefore not simply that an application contained a drafting error.

It is that:

a signed document allegedly containing an irrelevant ground of urgency was later altered, the signature was removed, and the altered version was then served.

Whether that happened exactly as alleged is a matter for documentary verification. But if the filing history substantiates it, the issue is considerably more serious than embarrassing drafting.

4. The Ankiti Bose connection makes the chronology even more striking

The Section 379 application makes another allegation that increases the forensic significance of the chronology.

It says essentially the same “restoration of possession” urgency language appeared in an earlier case:

CS(OS) No. 756/2026 — Ankiti Uday Bose v. Nitin Naresh & Ors.

According to the application, Defendant No. 1 appeared in person in the Bose proceeding on 9 September 2026 and objected that the urgency ground concerning restoration of possession was false. The application then says that on 10 September, the later version in the Krishan Rattan case no longer contained that disputed wording.

There is an important independent judicial record here.

On 24 August 2026, the Delhi High Court in the Ankiti Bose litigation had already granted interim protection concerning specified publications and restrained the defendants from disseminating the impugned material through social media, as well as from publishing further articles having the effect of restraining the plaintiff from exercising her legal rights. The Court’s order recorded that certain publications had the effect of deliberately portraying the plaintiff in a bad light and potentially affecting the court proceedings.

Then, on 14 September 2026, the Delhi High Court dealt with Krishan Rattan’s own defamation action, in which he relied upon the 5 August 2026 English consent order and alleged that publications continued despite the discontinuance of the English proceedings against him. The Court granted interim protection against further publications containing defamatory imputations, while observing that the interim order did not prevent legitimate fact-finding.

The chronology therefore matters:

Ankiti Bose suit → interim protection → dispute over urgency wording → Krishan Rattan suit → version changes alleged → Section 379 application.

That chain does not establish criminal conduct.

But it unquestionably explains why a defendant would ask the Court to examine the filing history rather than simply argue the defamation case.

5. The paragraph 46/49 changes and the ₹2 crore damages claim

The application goes further.

It alleges that paragraphs 46 and 49 of the plaint were materially rewritten after Version A, including changes to the description of defendants and the reliefs claimed.

Most notably, the applicant says an additional prayer was introduced concerning a public apology and that the court-fee valuation was increased by ₹200, with an additional ₹20 court fee, without a corresponding fresh affidavit.

The original plaint reproduced in the annexures seeks ₹2 crore in damages, with the damages relief valued accordingly and court fee of ₹1,97,544 shown in the pleading.

Again, the monetary difference itself is tiny.

That is precisely why the application does not really depend on the ₹200.

The point is documentary integrity.

If the relief portion of the pleading changed materially after a declaration had been sworn, the applicant argues that the Court should determine whether the declaration actually supported the pleading ultimately filed.

In litigation, a small number can sometimes expose a much larger procedural issue.

6. The Section 63 BSA certificate: the electronic-record problem

The most technically interesting portion of the application concerns the electronic evidence certificate.

The application alleges that the Section 63 certificate was dated 1 September 2026, but was subsequently relied upon in relation to versions of the pleading that were materially different.

It therefore asks a blunt question:

What electronic document exactly did the certificate certify?

The application cites Arjun Panditrao Khotkar v. Kailash Kushanrao Gorantyal, where the Supreme Court addressed the statutory certificate requirement for electronic evidence under the former Section 65B framework.

The filing then raises an additional issue concerning the NotarEase record.

According to the material reproduced in the application, the NotarEase verification displays:

• verification code WXK-MQK-2YY;
• notary Shivani Biswal;
• notarisation date 1 September 2026; and
• a reported page count of 12.

The application contends that the served plaint was a far larger compilation and asks the Court to obtain the underlying notarisation record and identify the precise twelve-page document associated with that verification.

That is a proper forensic question.

A QR code is not a substitute for the underlying audit trail. A stamp is not a substitute for the notarisation record. And a statement that a document was electronically signed is not necessarily identical to the evidentiary proposition that a cryptographically verifiable electronic signature was created.

The application therefore seeks the underlying records rather than asking the Court simply to accept screenshots.

7. “Authentication type: None” — a detail that demands verification

The application also points to the Zoho Sign records.

Its pleaded case is that the completion certificate records authentication type as “None” for the signatories, while the signing service itself offers multiple authentication mechanisms.

The annexure contains entries showing Krishan Rattan’s signing record and, separately, Shivani Biswal’s signing record, including an entry identifying the latter as having been “Signed using: Aadhaar eSign.”

That distinction is important.

The application is not merely asking whether an image visually resembling a signature appears on a PDF. It asks what underlying audit event actually took place, what authentication was used, what file was signed, and whether the final court filing is the same electronic object that generated the audit trail.

That is exactly the sort of question that should be answered by original server-side logs rather than competing narratives.

8. The application also raises an extraordinary three-country discrepancy

Another allegation concerns the Plaintiff’s location.

The application points to:

• an advocate defect remark referring to the Plaintiff as residing in Dubai;
• the affidavit/address describing him as residing in London; and
• a verification recording the act as being performed in Singapore.

All are said to relate to 1 September 2026.

This does not by itself establish falsehood.

A person can travel. A person can reside in one country and execute an electronic document while physically present elsewhere. Remote notarisation can also introduce complicated jurisdictional questions.

But that is exactly why the application seeks evidence.

Where was the Plaintiff?

Where did the notary act occur?

Was there a remote video appearance?

What system was used?

What audit logs exist?

What identity verification occurred?

These questions cannot responsibly be answered by political-style rhetoric or internet speculation. They can be answered by metadata, notarisation records, audit logs, device information and the original electronic files.

9. Then comes the bizarre “her” reference

The filing contains another allegation that is almost too conspicuous to ignore.

Krishan Rattan is identified throughout the cause title and memo of parties as a male plaintiff. Yet paragraph 49(e) reportedly seeks protection for content concerning “the Plaintiff, her professional work, business ventures, career, associations or affairs”, while paragraph 49(g) refers to injury to “her reputation” and “her professional standing.”

The Section 379 application argues that this may indicate that drafting material belonging to another case was reused without being properly adapted.

That is an allegation—not proof of fraud.

But it is also not insignificant when placed beside the separate allegation that the urgent application contained language concerning “restoration of possession of the Suit Property” and that similar wording appeared in the Ankiti Bose proceeding.

At some point, a collection of supposedly independent “typing errors” begins demanding an explanation of its own.

Krishan Rattan & Ankiti Bose: the wider public record

The Section 379 controversy cannot be properly understood without examining the public record surrounding Krishan Rattan and Ankiti Bose—while being careful not to turn contested allegations into convictions.

Rattan’s own Delhi plaint describes him as a banker, financial-services entrepreneur, investment professional and founding partner of Terra-Invest, and states that he has been involved in transactions aggregating more than US$12 billion, alongside senior positions at Société Générale, Deutsche Bank, Credit Suisse and Morgan Stanley. Those are claims made in his litigation pleadings; Terra-Invest’s own public profile similarly describes him as a founding partner.

Ankiti Bose is described in the same litigation as Rattan’s co-founder at Terra-Invest. Her earlier Delhi suit became the immediate legal backdrop to the Rattan litigation.

But Bose’s earlier corporate history at Zilingo is itself the subject of an extensive and contested public record.

In 2022, Zilingo suspended Bose and subsequently terminated her employment following an investigation into alleged financial irregularities. Zilingo publicly said the investigation had been conducted by an independent forensic firm. Bose disputed the process and said she had not been given access to the relevant reports or enough opportunity to respond.

Crucially, even contemporary reporting contains an important nuance sometimes lost in internet retellings: The Mint reported that Bose’s termination letter listed grounds including insubordination, neglect and failure to produce documents, while not accusing her of fraudulent transactions in the termination letter itself.

Bose later resigned from Zilingo’s board, saying she had not been shown the Kroll or Deloitte investigative reports.

Zilingo ultimately faced voluntary liquidation proceedings.

That sequence makes for uncomfortable reading.

But uncomfortable reading is not the same thing as proof that Bose committed fraud.

That distinction is exactly what responsible investigative journalism must preserve.

The same rule must apply to Krishan Rattan

There is an equally important qualification concerning Rattan.

The public record confirms his association with Voltaire Capital and the existence of substantial litigation in the English Commercial Court. Earlier proceedings involved civil-fraud claims and placed his name among the defendants.

But the story does not end there.

A 5 August 2026 consent order resulted in discontinuance of the claims against Rattan, and the Delhi High Court subsequently recorded that there had been no adverse finding of fraud, dishonesty or wrongdoing against him in those discontinued proceedings.

That means journalism cannot honestly compress the English litigation into the headline:

“Krishan Rattan was found to be a fraudster.”

The record does not establish that.

What it does establish is that he was a defendant in significant English proceedings, that serious allegations were made, and that the claims against him were subsequently discontinued without an adverse finding against him.

Those are three different facts.

The DLI ₹993-crore issue: another frequently misunderstood part of the story

There is also the issue of Distribution Logistics Infrastructure Pvt. Ltd. (DLI).

The applicant’s underlying material seeks to connect Rattan’s historical directorship with DLI’s subsequent insolvency. The Rattan plaint, however, states that he resigned on 19 June 2025, with cessation effective 20 June 2025, while insolvency proceedings commenced only on 14 May 2026.

The Insolvency and Bankruptcy Board of India record shows that CIRP commenced on 14 May 2026 and that, as of 6 June 2026, admitted claims of secured financial creditors totalled approximately ₹993.26 crore, against total claims received of approximately ₹1,018.55 crore.

Those figures are company-level insolvency figures.

They are not, by themselves, evidence that Krishan Rattan personally owed ₹993 crore, diverted ₹993 crore, or was personally responsible for DLI’s insolvency.

That distinction matters enormously when a headline converts a corporate insolvency figure into an individual’s supposed financial wrongdoing.

What makes the Section 379 application strategically significant?

The application is strategically different from a normal written statement in a defamation case.

The underlying defamation suit asks:

Were the publications lawful, accurate, fair and otherwise defensible?

The Section 379 application asks a different question:

Was the litigation record itself prepared, verified, notarised and filed correctly?

That creates a second battlefield.

And it is potentially more consequential because the requested evidence is largely objective:

the original e-file, Registry metadata, refiling history, document hashes or audit data where available, NotarEase records, notarial register, Zoho Sign audit trail, authentication records and the versions served on the defendants.

That is why the application repeatedly asks for production of records rather than asking the Court simply to adopt the applicant’s allegations. Its prayer seeks the Registry’s filing history and scrutiny record, NotarEase documentation and the electronic audit trail before the Court decides whether a criminal complaint is warranted.

In other words:

the application is asking the paper trail to speak.

The uncomfortable question the Court may ultimately have to answer

A court is perfectly capable of forgiving a typographical error.

Courts routinely see bad formatting, accidental omissions, incorrect dates and drafting mistakes.

The issue becomes qualitatively different where several alleged discrepancies converge:

A plaint allegedly exists in two materially different versions.

A factual paragraph allegedly changes.

An urgency application allegedly refers to a non-existent “Suit Property”.

The same urgency wording allegedly appears in another proceeding.

The signature allegedly disappears from the later version.

Paragraph 49 allegedly changes.

A valuation allegedly changes.

A Section 63 certificate allegedly remains unchanged.

A notarisation record allegedly refers to twelve pages.

The file allegedly contains image representations of signatures and stamps.

The location of the deponent allegedly shifts among Dubai, London and Singapore.

And a pleading allegedly describes a male plaintiff’s professional affairs using “her”.

Any one of those facts, standing alone, may have an innocent explanation.

The legal question is whether the explanations survive a forensic examination of the original records when considered together.

That is why the application seeks an inquiry rather than demanding that the Court simply pronounce guilt.

This is where the Krishan Rattan & Ankiti Bose story becomes bigger than another media-versus-businessman fight

There is a temptation in modern litigation to reduce every dispute into two camps:

“The journalist is attacking the businessman.”

Or:

“The businessman is suppressing journalism.”

That binary is too convenient.

The Delhi High Court has already been asked to balance competing interests in both the Bose and Rattan proceedings. In Rattan’s September 2026 case, the Court granted interim protection against further defamatory imputations while making clear that the order did not prevent fact-finding.

The Section 379 application now takes that fact-finding principle and turns it inward—towards the litigation documents themselves.

That creates an important institutional question:

If the publications are to be tested against the public record, shouldn’t the integrity of the documents placed before the Court be tested with the same seriousness?

The answer should not depend upon whether the litigant is a startup founder, investor, journalist, celebrity or ordinary citizen.

The court record has to mean what it says.

The “dark history” narrative needs one important correction

There is enough material in the public domain to construct an aggressively negative narrative around Krishan Rattan & Ankiti Bose.

There have been high-profile corporate failures, contested governance disputes, employment controversies, insolvency proceedings, cross-border litigation, reputational lawsuits and increasingly hostile legal battles.

But journalism should resist the easiest—and least defensible—shortcut:

turning association into guilt.

A former directorship is not proof of misappropriation.

A civil-fraud allegation is not a criminal conviction.

A corporate insolvency is not automatically an individual’s financial crime.

A termination following an investigation is not automatically a fraud conviction.

And a Section 379 application is not a perjury conviction.

Those distinctions do not make the story weaker.

They make the story harder to knock down.

What should happen now?

If the allegations in the Section 379 application have no evidentiary foundation, the matter should be resolved quickly and transparently.

If the records confirm material alterations, unexplained inconsistencies, false declarations or other wrongdoing affecting the administration of justice, then the statutory machinery should be allowed to operate without unnecessary delay.

The appropriate course is therefore speed, preservation of evidence and forensic verification—not endless procedural theatre.

The Registry should have the complete e-filing and refiling history.

The original electronic files should be preserved.

The relevant notarisation and signing audit trails should be obtained.

The parties should be given an opportunity to explain discrepancies.

And if the evidence establishes a criminal offence, the competent authorities should act promptly in accordance with law.

Conversely, if the evidence does not support the allegations, that conclusion should also be reached quickly.

A judicial system cannot afford years of ambiguity over whether a document presented to a court was the document actually sworn and notarised.

Conclusion: the real issue is not the headline—it is the file

The Krishan Rattan & Ankiti Bose saga already contains enough conventional controversy: Zilingo, Terra-Invest, Voltaire, DLI, defamation litigation, injunctions, corporate disputes and competing versions of events.

But the most consequential issue raised by the September 2026 application is narrower and far more fundamental.

What document was actually sworn?
What document was actually notarised?
What document was actually served?
What document was ultimately filed?
And did the supporting declarations truthfully correspond to that document at the relevant time?

Those are not questions that should be answered through headlines.

They should be answered through the Registry record, the original files, audit trails, notarial records and judicial scrutiny.

The Section 379 application therefore deserves to be viewed not as a colourful extension of a media feud, but as a direct challenge to the integrity of the litigation record.

And that is precisely why it matters.

Because reputations can be argued about.

Headlines can be challenged.

Corporate histories can be interpreted.

But the court record should be capable of being independently verified.

That is the standard the legal system owes to everyone—including Krishan Rattan, Ankiti Bose, Nitin Naresh, the journalists involved, and ultimately the Court itself.

Strong legal and editorial disclaimer

Disclaimer: This article is an investigative analysis based on the September 2026 Section 379 BNSS application and publicly accessible court, regulatory and corporate records. The allegations contained in the application are allegations and have not been treated in this article as established facts. The filing of an application under Section 379 BNSS does not amount to a conviction for perjury or false evidence. Based on the records reviewed, no court of law has convicted Krishan Rattan of perjury in relation to the matters discussed here. The English proceedings involving Rattan were discontinued against him by consent in August 2026 without an adverse finding of fraud, dishonesty or wrongdoing as subsequently recorded by the Delhi High Court.

With respect to Ankiti Bose, contemporary reporting confirms her suspension and subsequent termination by Zilingo following an investigation into alleged financial irregularities, while Bose disputed the allegations and the process and maintained that she had not been provided the relevant investigative reports. The available material does not justify presenting those disputed allegations as a criminal conviction against her.

The approximately ₹993.26 crore figure discussed above relates to admitted secured financial-creditor claims in DLI’s insolvency process and should not be portrayed, without separate evidence, as a personal liability or criminal liability of Krishan Rattan.

Given the seriousness of the allegations concerning the integrity of documents presented in court, any inquiry should be conducted expeditiously, evidence should be preserved immediately, and—where the statutory threshold is met—appropriate criminal or regulatory action should follow without avoidable delay. Equally, where allegations are unsupported, they should be brought to a clear and speedy end. Due process must operate in both directions.