Introduction:
In a significant ruling, the Karnataka High Court on August 28, 2025, dismissed a Public Interest Litigation (PIL) that sought judicial intervention to direct prominent political figures, including the Leader of Opposition Rahul Gandhi and Lok Sabha Speaker Om Birla, to provide clarity on the existence of an alleged ‘Volume 2’ of Mahatma Gandhi’s autobiography, My Experiments with Truth, which was claimed to be missing from the public domain. The petition was filed by an organization named Jagrutha Karnataka, Jagrutha Bharatha, represented through its President K. N. Manjunatha, who appeared in person. The case, titled Jagrutka Karnatak Jagrutha Bharata v. The Secretary & Others, was registered as WP 33695/2025 and cited as 2025 LiveLaw (Kar) 289. A division bench comprising Chief Justice Vibhu Bakhru and Justice C. M. Joshi presided over the matter and delivered the order dismissing the PIL.
The petitioner argued that while undertaking research into the British era and modern Indian history, he discovered distortions, gaps, and inconsistencies in the historical narrative presented in mainstream sources and textbooks. According to him, these omissions were at the root of the current political instability, ideological conflicts, and social chaos that India faces today. In particular, he claimed that crucial events from the period between 1926 and 1947, a transformative era in India’s freedom struggle and the eventual partition, were absent from existing historical accounts. He asserted that these missing elements were supposedly covered in a ‘Volume 2’ of Gandhi’s autobiography, which, according to him, had either gone missing or had been deliberately concealed from the public domain. In his PIL, Manjunatha further sought interim directions to compel authorities to produce a photograph allegedly depicting Mahatma Gandhi participating in the celebrations of Indian independence on August 15, 1947, contending that this visual evidence was necessary to shed light on the historical questions he had raised in his research letters.
The petitioner placed reliance on his scholarly endeavor, stating that he had already addressed letters to several authorities, including political leaders and constitutional functionaries, requesting their intervention in bringing this alleged missing volume to light and in clarifying historical distortions. However, he emphasized that his letters were met with silence, prompting him to approach the constitutional courts for relief. He positioned his PIL as an effort to “enlighten the nation” about its true history, particularly regarding Gandhi’s role in the crucial period leading up to independence and partition. His plea urged the Court to recognize that history, as currently taught and understood, contains “distortions and gaping holes,” which must be corrected for the larger public good.
Arguments of the Petitioner:
K. N. Manjunatha, arguing in person, presented a detailed narrative about his research and the reasons behind filing the petition. His primary contentions were as follows. First, he argued that the absence of information about significant events in Indian history from mainstream narratives has created confusion and discord in the political landscape of modern India. He maintained that such omissions have resulted in an incomplete understanding of the freedom struggle, Gandhi’s role, and the factors that led to partition. According to him, this incomplete narrative misguides citizens and prevents younger generations from grasping the true sacrifices and decisions that shaped India’s destiny.
Second, he asserted the existence of a “Volume 2” of Gandhi’s autobiography, which he claimed had been suppressed or lost. He argued that the first volume of My Experiments with Truth ends around 1926, while Gandhi remained active in the independence movement until his assassination in 1948. Therefore, logically, a second volume covering the crucial years between 1926 and 1947 must exist. According to him, retrieving this volume was essential for clarifying the narrative of India’s independence and partition.
Third, the petitioner argued that he had exhausted all avenues of communication with the authorities by addressing letters to several individuals and institutions, including Rahul Gandhi, the Leader of Opposition, and Om Birla, the Speaker of the Lok Sabha. Since his concerns had been ignored, he believed judicial intervention was the only option left to address what he considered a matter of public interest.
Finally, he requested an interim direction from the Court to ensure the production of a photograph that allegedly showed Mahatma Gandhi actively participating in India’s independence celebrations on August 15, 1947. He argued that such a photograph, if produced and authenticated, would substantiate his broader claim that certain historical facts were missing or deliberately concealed from public discourse. By seeking judicial directions to political leaders and constitutional authorities, he framed his petition as a means to uncover truth and correct historical distortions for the benefit of the nation.
Response of the Respondents:
The petition, however, faced critical questions from the Bench regarding its maintainability and the nature of relief sought. The respondents, represented by the State and Union authorities, argued that the petition lacked specificity, legal foundation, and justiciability. They contended that the judiciary cannot be expected to issue directions compelling individuals or authorities to produce missing historical documents or to rewrite history. The respondents highlighted that history is a subject of academic inquiry, not judicial mandate, and courts cannot entertain petitions based on speculative claims or vague assertions.
Furthermore, it was submitted that the petitioner had not presented any verifiable proof of the existence of a “Volume 2” of Gandhi’s autobiography. The autobiography, as published and known globally, concludes in 1926, and there has been no credible scholarly reference to a continuation authored by Gandhi himself. Therefore, the request to direct authorities to produce a non-existent volume was inherently untenable.
Additionally, the respondents argued that judicial time should not be diverted to address questions that fall squarely within the realm of academic research, archival studies, and historical scholarship. Courts are not equipped to adjudicate disputes about missing historical records or to enforce historical clarifications, especially when the petitioner’s claims rest solely on conjecture. The request for producing a photograph of Gandhi at independence celebrations was also dismissed as irrelevant, speculative, and incapable of being enforced through judicial directions.
Court’s Judgment:
After hearing the petitioner and considering the submissions, the Karnataka High Court dismissed the PIL. Chief Justice Vibhu Bakhru, delivering the observations of the Bench, emphasized that the petition was fundamentally misconceived and incapable of being entertained under constitutional jurisdiction. The Court observed that while the petitioner’s concerns about distortions in history may reflect his personal convictions, no legal relief can be granted on such grounds.
The Court categorically held that “according to the petitioner, there are gaps in history which need to be answered. Clearly, no order can be issued in this regard. If the petitioner wishes to undertake the scholarly exercise of doing research in history, there is no impediment for the petitioner in doing so.” This observation made it clear that the judiciary cannot act as an arbiter of historical truth or compel the discovery of documents whose existence itself remains unproven.
With respect to the petitioner’s claim of a missing “Volume 2” of Gandhi’s autobiography, the Bench found the request to be vague and without substance. The Court noted that Gandhi’s autobiography, as published, is universally recognized to cover the period until 1926, and there is no evidence of a subsequent volume authored by him. Thus, the prayer for recovering such a volume was dismissed as baseless.
The Bench further refused to grant any interim direction regarding the production of a photograph showing Gandhi at independence celebrations. It observed that such a relief was beyond the scope of judicial proceedings and lacked any enforceable basis. The Court clarified that historical questions are best left to scholars, researchers, and academic institutions, and the judiciary cannot be burdened with adjudicating speculative claims about archival material.
In conclusion, the Karnataka High Court dismissed the PIL in its entirety, holding that the petition failed to raise any legally enforceable issue and that no directions could be issued in the manner sought by the petitioner.