Fraud on Court, in pari delicto

Satpal Singh Arora v. Santdas Prabhudas Malkani, (1970) 73 BLR 777 (relevant page 789 of the judgement) which, inter alia, holds that if in a Suit it is established that both the parties intended to play fraud upon law to circumvent its provisions, the maxim in pari delicto, potior est condition defendatis, i.e. where both parties are equally at fault, the position of the Defendant is stronger, will apply.

 S. P. Chengalvaraya Naidu v. Jagannath 1994 (1) SCC 1 (relevant paragraphs 5 & 6), the Hon'ble Supreme Court has held that if a Plaintiff's case is based on fraud he can be thrown out at any stage.