Thursday, 28 May 2026

Supreme Court: It is mandatory for police to obtain permission of Magistrate for doing further investigation

 Even though the statute does not require express permission, the law as it has developed, has made abundantly clear that seeking of permission from the concerned Magistrate has evolved into a requirement. In Vinay Tyagi v. Irshad Ali 6, it has been held as follows:

“49. Now, we may examine another significant aspect which is how the provisions of Section 173(8) have been understood and applied by the courts and investigating agencies. It is true that though there is no specific requirement in the provisions of Section 173(8) of the Code to conduct “further investigation” or file supplementary report with the leave of the court, the investigating agencies have not only understood but also adopted it as a legal practice to seek permission of the courts to conduct “further investigation” and file “supplementary report” with the leave of the court. The courts, in some of the decisions, have also taken a similar view. The requirement of seeking prior leave of the court to conduct “further investigation” and/or to file a “supplementary report” will have to be read into, and is a necessary implication of the provisions of Section 173(8) of the Code. The doctrine of contemporanea expositio will fully come to the aid of such interpretation as the matters which are understood and implemented for a long time, and such practice that is supported by law should be accepted as part of the interpretative process.

NON-REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. ______________________ OF 2026

(@ Special Leave Petition (Crl.) 16149 of 2024)

PALINISWAMY VEERARAJA & ORS. Vs  THE STATE OF KARNATAKA & ANR. 

Author: SANJAY KAROL, J.

Citation: 2026 INSC 561.

Dated: May 26, 2026

Leave Granted

2. Paliniswamy Veeraraja, K. Paliniswamy, Ammani and R. Kavitha, the four

accused in CC No. 55623 of 2014 arising out of Crime No. 209 of 2006 under

sections 406, 468, 471, 420 r/w 34 of the Indian Penal Code,18601, are before us

challenging the High Court’s2 decision to decline the prayer for quashing3 of the

case pending on the file of the 10th Additional Chief Metropolitan Magistrate,

Bangalore City.

1 IPC

2 High Court of Karnataka at Bengaluru

3 Criminal Petition No. 4624 of 2022


3. The background facts as have been noticed by the Court below are as

follows:

(i) The accused together run M/s Kay Pee Exporters who export

textiles and related products. Accused Nos. 1 and 2, the managing

partners of the firm, in the course of business, came in contact with

Respondent No. 2 who is the private complainant, and ran businesses

similar in nature to the Accused, in the United States of America and

Canada;

(ii) They developed a mutually beneficial business relationship wherein

the complainant allegedly had to invest money into the business of

the accused, in the form of aiding its expansion into these markets

and in turn he would be entitled to 1/3rd profits of this venture;

(iii) The complainant’s case is that, upholding his end of the bargain, he

periodically made investments into the business and also promoted a

company by the name M/s Associated Textile Inc, established as per

the laws of the Illinois State, but the accused had no intent of

honouring their part. On the other hand, the appellants herein

maintain that there was nothing in the nature of a joint venture

between the parties since one of the aspects floated by the

complainant was that the appellant’s firm should exclusively supply

to him, which they were not agreeable to in the least;

(iv) Finding the situation to be so, a case was instituted in the Northern

District of Illinois being Associated Textile Inc. v. Paliniswamy

Veeraraja4. The District Court granted the motion for entry of final

judgment against the Respondents (ex parte) and granted total

damages of $2,268,222.46., on 2nd February 2004. The findings of

4 No. 01C6249


the Court are relevant for the present determination. As such, they

are extracted as under:-

“It is hereby ordered and adjudged as follows:-

1. Judgment is entered in favour of Plaintiff Associated

textile, Inc, and against Defendants Palaniswamy

Veeraraja and Kaypee Exporters, jointly and severally, on

Counts I (Accounting Breach of Joint Venture

Agreement), II (Accounting; Fraudulent Inducement), and

IV (Accounting Unjust Enrichment) of Plaintiff’s

Complaint, in the total amount of TWO MILLION TWO

HUNDRED SIXTY-EIGHT THOUSAND TWO

HUNDRED TWENTY-TWO DOLLARS AND

FORTY-SIX CENTS ($2,268,222.46), as follows:-

(a) Compensatory damages of ONE MILLION

ONE HUNDRED THIRUTY FOUR THOUSAND ONE

HUNDRED ELEVEN DOLLARS AND TWENTYTHREE

CENTS ($1,134,111.23), plus costs and postjudgment

interest at the statutory rate plus.

(b) Punitive damages of an additional ONE

MILLION ONE HUNDRED TWENTY-THREE

CENTS ($1,134,111.23).

2. Further, Defendants Palaniswamy Veeraraja and

Kaypee Exporters are enjoined and ordered to provide

Plaintiff Associated Textile, Inc., a full and complete

accounting of all revenues, profits and proceeds from

Defendant Kaypee Exporters sales of textiles to the U.S.

and Canada from 01.01.1996 to present.

3. Further, a constructive trust is hereby imposed for the

benefit of Plaintiff Associated textile, Inc., upon (a) onethird

of the profits shown by an accounting to have been

wrongfully appropriated and retained by Defendants

Palaniswamy Veeraraja and/ or Kaypee Exporters, (b) the

proceeds there from, and / or (c) the interest or other

return which the Defendants earned or could have

reasonably earned thereon.

4. Further, judgment is entered in favour of Plaintiff

Associated Textile, Inc and against Defendants

Palaniswamy Veeraraja and Kaypee Exporters, on all

counts of Defendants Counterclaim. Defendants shall take

nothing, and are entitled to no payment, credit or set off

from Plaintiff.”


(v) Shortly thereafter, he filed a complaint under Section 200 Code of

Criminal Procedure, 1973 before the City Civil and Sessions Court,

Bangalore, that led to the present proceedings;

(vi) Pursuant to the complaint, the matter was taken up for investigation

by the Indra Nagar Police Station on 9th August 2006. On 17th

November 2006, a closure report was filed recording that the dispute

between the parties is entirely civil in nature;

(vii) On 1st September 2007 the complainant filed an application under

Section 173(8) CrPC seeking permission for further investigation.

The same was dismissed by an order dated 8th October 2007. Shortly

thereafter, a criminal miscellaneous petition was filed to restore the

complaint and direct further investigation which came to be allowed

by Sessions Court on 31st May 2010;

(viii) A second closure report was filed on 22nd November 2011. But then

again on 25th February 2012 Police Inspector Indiranagar, sought to

continue investigation after filing application under Section 173(8)

CrPC;

(ix) Chargesheet was filed on 25th September 2013.

(x) The appellants contend to be unaware of all these proceedings till

May 2022;

(xi) It may also be noted that the suit for recovery of money filed against

the appellants was dismissed by the XXXIIIrd Additional City Civil

and Sessions Judge, Bangalore, on 5.11.2014 on account of the fact

that the same had been decided ex-parte; and

(xii) On coming to know of these proceedings, the appellants filed the

quashing petition Criminal Petition No.4624 of 2022 before the High

Court of Karnataka.


4. The High Court, in terms of the impugned judgment dismissed the

petition for quashing rejecting the appellants’ arguments of jurisdiction not

vesting with the Courts at Bangalore, and also the argument that the offence in

question took place outside India. According to the Court, a prima facie case was

made out against the appellants’ herein.

5. Ms. V. Mohana, learned senior counsel appearing for the appellants

strongly questions the findings of the High Court submitting inter alia as

follows:

a) That closure report had been filed twice earlier recording that the dispute

appears to be entirely civil in nature. On the third instance that investigation was

sought to be conducted, the same was done without the permission of the

competent authority to conduct further investigation;

b) None of the ingredients of cheating or forgery are made out and the dispute

at hand is entirely civil in nature;

c) The impugned judgment considered only the factum of a private complaint

vis a vis section 195(1)(b)(ii) of the Code of Criminal Procedure 1973 and did not

consider anything else;

d) The Court has entirely missed the fact that there is no finding on the

allegations of forgery by the appellants regarding documents submitted in the

foreign Court in the judgment of the foreign Court itself;

e) The alleged cheating or forgery that took place was between 1996 to 2000.

The complaint for allegedly false documents was filed only in 2004. The delay is

unexplained; and

f) All allegations whatsoever, do not, neither in any way pertain to appellant

nos. 3 and 4 and nor has any role been attributed to them. Therefore, if this

Hon’ble Court is not inclined to accept the submissions made on behalf of

appellant nos.1 and 2, the proceedings may, at the very best, be closed in so far

as appellant nos.3 and 4 are concerned.


6. On the other hand, Mr. Prateek Chadha learned Additional Advocate

General appeared for the State of Karnataka and Mr. Gaurav Agrawal, senior

advocate appeared for the complainant - respondent no.2. submitted as follows:-

a) The remittance of amounts by the complainant to the appellants is

an admitted fact and despite the former having done his part, the latter

did not carry out the agreed scenario of sharing profits;

b) The District Court, Illinois found the complainant’s case to be

justified on four counts i.e., (i) breach of joint venture agreement; (ii)

fraudulent inducement; (iii) tortuous interference with contract; and (iv)

unjust enrichment;

c) 28 out of the 119 documents were found to be forged. They carried

the name and signature of the complainant but upon being examined by

handwriting experts at the instance of the complainant, it was found that

they were fabricated. This shows the fraudulent intent on part of the

appellants; and

d) The appellants’ submission regarding violation of Section 173(8)

CrPC is unjustified for the reason that the text of the statute does not

preclude the investigating agency from conducting further investigation

upon discovery of additional material.

7. The State supports the case of the respondent no. 2.

8. We now consider the rival contentions. The short question which arises

for consideration is whether it was open for the investigating authorities to

initiate further investigation into the same set of allegations after closure report

had been filed twice and whether the same could have been done in the absence

of express permission from the Magistrate. A secondary question in these facts


is whether the dispute inter se parties is civil in nature and, therefore, the recourse

to criminal law would be unjustified.

9. On both these questions, the law is no longer res integra. True it is that, as held in Rama Chaudhary v. State of Bihar 5, the text of Section 173(8)CrPC does not explicitly mandate seeking of permission from the Magistrate and neither does 193(9) BNSS. However, the proviso to the said Section mandates that permission of the Court is explicitly required once the trial has begun. Even though the statute does not require express permission, the law as it has developed, has made abundantly clear that seeking of permission from the concerned Magistrate has evolved into a requirement. In Vinay Tyagi v. Irshad Ali 6, it has been held as follows:

“49. Now, we may examine another significant aspect which is how the provisions of Section 173(8) have been understood and applied by the courts and investigating agencies. It is true that though there is no specific requirement in the provisions of Section 173(8) of the Code to conduct “further investigation” or file supplementary report with the leave of the court, the investigating agencies have not only understood but also adopted it as a legal practice to seek permission of the courts to conduct “further investigation” and file “supplementary report” with the leave of the court. The courts, in some of the decisions, have also taken a similar view. The requirement of seeking prior leave of the court to conduct “further investigation” and/or to file a “supplementary report” will have to be read into, and is a necessary implication of the provisions of Section 173(8) of the Code. The doctrine of contemporanea expositio will fully come to the aid of such interpretation as the matters which are understood and implemented for a long time, and such practice that is supported by law should be accepted as part of the interpretative process.

This proposition was approved in Vinubhai Haribhai Malaviya v. State of Gujarat 7 and reiterated in Peethambaran v. State of Kerala 8. Recently, in

5 (2009) 6 SCC 346

6 (2013) 5 SCC 762

7 (2019) 17 SCC 1

8 (2024) 16 SCC 65


Robert Lalchungnunga Chongthu v. State of Bihar 9, this Bench observed as

follows:

“21. Before parting with this matter, we deem it fit to issue the

following directions:

(i) In view of Vinay Tyagi v. Irshad Ali, it can be seen that the ‘leave of the court’ to file a supplementary chargesheet, is a part of Section 173(8) CrPC. That being the position, in our considered view, the Court is not rendered functus officio having granted such permission. Since the further investigation is being made with the leave of the Court, judicial stewardship/control thereof, is a function which the court must perform.

(ii) Reasons are indispensable to the proper functioning of the

machinery of criminal law. They form the bedrock of fairness,

transparency, and accountability in the justice system. If the Court

finds or the accused alleges (obviously with proof and reason to

substantiate the allegation) that there is a large gap between the

first information report and the culminating chargesheet, it is

bound to seek an explanation from the investigating agency and

satisfy itself to the propriety of the explanation so furnished.

The direction above does not come based on this case alone. This

Court has noticed on many unfortunate occasions that there is massive

delay in filing chargesheet/taking cognizance etc. This Court has time

and again, in its pronouncements underscored the necessity of speedy

investigation and trial as being important for the accused, victim and

the society. However, for a variety of reasons there is still a lag in the

translation of this recognition into a reality.

(iii) While it is well acknowledged and recognised that the process of

investigation has many moving parts and is therefore impractical to

have strict timelines in place, at the same time, the discussion made in

the earlier part of this judgement, clearly establishes that

investigations cannot continue endlessly. The accused is not out of

place to expect, after a certain point in time, certainty- about the

charges against him, giving him ample time to preparing plead his

defence. If investigation into a particular offence has continued

for a period that appears to be unduly long, that too without

adequate justification, such as in this case, the accused or the

complainant both, shall be at liberty to approach the High Court

under Section 528 BNSS/482 CrPC, seeking an update on the

investigation or, if the doors of the High Court have been

knocked by the accused, quashing. It is clarified that delay in

completion of investigation will only function as one of the

grounds, and the Court, if in its wisdom, decides to entertain this

application, other grounds will also have to be considered.

9 2025 SCC OnLine SC 2511


(iv) Reasons are not only important in the judicial sphere, but they are

equally essential in administrative matters particularly in matters such

as sanction for they open the gateway to greater consequences.

Application of mind by the authorities granting or denying sanction

must be easily visible including consideration of the evidence placed

before it in arriving at the conclusion.

[emphasis in original]”

10. Record reveals that although an application had been filed before the concerned Magistrate for further investigation a third time around, no order specifically granting permission is appended on record, neither it is a submission of the party that permission stood granted. In view of the above judgments, submission of respondent no.2 that permission is not required has to be negated.

11. On this short ground alone, the First Information Report and the eventual chargesheet could be quashed, set aside and the matter would be put to rest. Even otherwise, in view of the fact that proceedings inter se the parties have been ongoing for a considerable period of time, doing so would leave open the possibility of another round of litigation and as such we proceed to examine the merits of the matter.

12. The appellants and the respondents are both business owners. They allegedly entered into an agreement where one party would make monetary investment and the other would supply textile goods. One party says that the relationship continued without any incident between 1995 and 2000 and it is only thereafter that disputes arose regarding the nature of arrangement particularly an attempt to make the agreement between the parties exclusive which the appellants were not in favour of, did the dispute arise. On the other hand, the other party says that they had entered into an agreement and the very terms of the initial agreement itself were not complied with i.e., sharing of profits in return of capital investment in so far as the trading of textiles in USA and Canada is concerned. Either way, it is plain as day that the dispute between the parties concerns the business relationship or in other words concerning whether or not a joint venture stood established between them and if yes, the distribution

of profits arising therefrom. That clearly is in the nature of civil dispute.

13. When it comes to alleged forgery of documents, why is it that the

allegation came only in the Court in Bangalore and the suit filed before the

District Court Illionis, does not make any mention of the same. After all it is

before that Court that the alleged forged documents were filed. Still further, the

report of the handwriting expert on which reliance is placed to prove that the

documents were forged is dated prior to the judgment of the District Court i.e.,

1st September 2009 and the judgment was entered on 2nd February 2004. It only

stands to reason that if such hard, conclusive evidence was in the possession of

the complainant, the same could have been furnished to the Court and if

accepted, could have led to further punitive damages being awarded in his

favour. This obviously was not done. It be clarified here itself that the sanctity

of the report of the handwriting expert has not been examined by us and so we

do not comment thereupon. It is only the timing or the sequence of events that

renders the reliance placed thereon, suspect, in our considered view.

14. It is also a matter of record that for the reasons as recorded in the judgment, the civil suit of the complainant has also been dismissed. Well, we do not comment on the merits of that case and the complainant is obviously free to take recourse to the law as he may be advised if not already taken.

15. In the cumulative view of circumstances prevailing in this case, criminal action against the appellants would be contrary to the authority of law and therefore an abuse of process of law for the reason that the third round of further investigation as a consequence of which the chargesheet was filed, did not have the concerned Magistrate’s approval. That apart, in view of ground (3)mentioned in Para 102 of State of Haryana v. Bhajan Lal 1992 Supp (1) SCC 335, the FIR and subsequent proceedings which is the subject matter of the present appeal as mentioned in Para-1 are quashed and set aside.

16. Appeal is allowed accordingly. Pending application(s), if any shall stand

disposed of.

……………….………….…………………..J.

(SANJAY KAROL)

……………..…………………………………J

(NONGMEIKAPAM KOTISWAR SINGH)

New Delhi;

May 26, 2026


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