Gandhi is one of several top opposition leaders facing criminal proceedings, which they claim are politically motivated by the Modi government.
Last year he was sentenced to two years in prison till 2023 in a separate case in Gujarat, but was spared after he appealed to India's top court.
However, the conviction led to his disqualification from Parliament for a period of time, until the Supreme Court suspended his sentence.
On Friday, he made another brief court appearance in a case filed by a BJP member in technology hub Bengaluru, in which he had accused the BJP of corruption in the administration of the southern state of Karnataka.
US think tank Freedom House said this year that the BJP was “increasingly using state institutions to target political opponents.”
Delhi Chief Minister Arvind Kejriwal, an ally of Gandhi, was jailed this year in a corruption case.