Ramachandraiah v. M. Manjula

Judgment: https://lawyerslibrary.in/books/erpp/
Citation: 2025 INSC 556
Court: Supreme Court of India, Criminal Appellate Jurisdiction
Bench: Dipankar Datta, *Prashant Kumar Mishra, JJ.
Date of Decision: April 23, 2025
Case Numbers: Criminal Appeal Nos. of 2025 (Arising out of SLP (Crl.) Nos. 10449/2022 and 10515/2022)
Case Name: Ramachandraiah & Anr. v. M. Manjula & Ors.; D.A. Srinivas & Anr. v. M. Manjula & Ors.

[Arising out of impugned final judgment and order dated 03-09-2022 in WP No.7784/2022 passed by the High Court of Karnataka at Bengaluru]

Subjects

CBI Investigation, Magistrate Jurisdiction, FIR Registration, Constitutional Court Powers, Murder Probe, Property Dispute, Will Forgery, SIT Investigation.

Held

1. The appellants’ challenge to the FIR registration was not maintainable, as their earlier petition under Section 482 Cr.P.C. was withdrawn, rendering the issue final and binding.
2. The High Court’s direction for CBI investigation was upheld, as Constitutional Courts have extraordinary powers to order such probes sparingly in exceptional cases to ensure credibility, public confidence, and complete justice, as established in Vinay Tyagi v. Irshad Ali (2013) 5 SCC 762 and Pooja Pal v. Union of India (2016) 3 SCC 135. The mysterious death, conflicting Wills, and defective SIT investigation justified CBI involvement.
3. Prospective accused have no right to be heard at the investigation stage, per Union of India v. W.N. Chadha (1993) Supp (4) SCC 260.
4. Appeals dismissed, CBI directed to complete investigation within eight months, with the State of Karnataka to provide assistance. Case papers to be transferred to CBI within 15 days.

For Petitioner(s) :Mr. G. Balaji, AOR Ms. Mahalakshmi Pavani, Sr. Adv. Signature Not Verified Mr. Tomy Chacko, AOR Mr. Neeleshwar Pavani, Adv. Ms. Shaurya Mishra, Adv.

For Respondent(s) :Mr. Mahesh Thakur, AOR Ms. Anuparna Bordoloi, Adv. Mrs. Geetanjali Bedi, Adv. Mr. Ranvijay Singh Chandel, Adv. Ms. Anusha R, Adv. Mr. Devadatt Kamat, Sr. Adv. Mr. Nishanth Patil, A.A.G. Mr. V. N. Raghupathy, AOR Mr. Revanta Solanki, Adv. Mr. Ayush P. Shah, Adv. Mr. Vignesh Adithiya S, Adv. Mr. K. M. Nataraj, A.S.G. Mr. Mukesh Kumar Maroria, AOR Mr. V. V. V. Pattabhi Ram, Adv. Mr. Prashant Rawat, Adv. Mr. Purnendu Bajpai, Adv. Mr. Rajat Nair, Adv. Mr. Raman Yadav, Adv. Mrs. Khushboo Aggarwal, Adv. Mr. Sharath Nambiar, Adv. Mr. Paras Nath Singh, AOR Mr. Rizwan Ahmad, Adv. Mr. Shakeel Ahmed, Adv. Mr. Sadashiv, AOR Mr. Pranav Kumar Srivastva, Adv. Mr. Sachin Agarwal, Adv. Mr. Nishant Sanjay Kumar Singh, Adv. Mr. Prashant Andrew Leo, Adv. Mr. Ashish Singh, Adv. Mr. Sunil Kumar, Adv. Ms. Mumtaz Javed Shaikh, Adv. Ms. Vandana, Adv. Mr. Devendra Kumar Gupta, Adv.

Facts

The appeals challenged the Karnataka High Court’s order dated 03.09.2022, which partially allowed a writ petition by M. Manjula (Respondent No. 1), setting aside the Magistrate’s orders of 21.02.2022 and 10.03.2022 directing further investigation by HAL Police Station in the alleged murder of her husband, K. Raghunath, a successful realtor with significant assets. The High Court issued a mandamus directing the Central Bureau of Investigation (CBI) to investigate three related FIRs (Crime Nos. 89/2020, 148/2020, and 7/2021). Raghunath’s death on 04.05.2019 was initially treated as suicide (UDR No. 28/2019), but Manjula filed a private complaint (P.C.R. No. 51691/2020) alleging murder by Respondents 12–14, linked to property disputes and a contested Will. A Special Investigation Team (SIT) filed a ‘B’ report, which the Magistrate rejected for inadequate investigation, prompting the High Court’s CBI directive. The appellants, including alleged conspirators and relatives of the deceased, contested the CBI investigation and the Magistrate’s jurisdiction.

Procedural History

• Magistrate Court: Ordered FIR registration (Crime No. 89/2020) on 02.03.2020 based on the private complaint. Rejected SIT’s ‘B’ report on 21.02.2022, directing further investigation by HAL Police Station.
• Karnataka High Court: In Writ Petition No. 7784/2022, set aside the Magistrate’s orders for HAL Police investigation, finding them beyond jurisdiction, and directed CBI investigation within six months.
• Supreme Court: Appellants challenged the High Court’s CBI directive, arguing jurisdictional errors and procedural irregularities.

Issues

1. Whether the Magistrate had jurisdiction to direct FIR registration and further investigation for an offence triable by the Sessions Court based on a private complaint.
2. Whether the High Court was justified in directing a CBI investigation.

Arguments

• Appellants (via Aman Lekhi):
  • The Magistrate lacked jurisdiction under Sections 190(1)(a) and 202 Cr.P.C. to direct FIR registration for a Sessions-triable offence post-closure of unnatural death proceedings (Section 174 Cr.P.C.).
  • The private complaint was belated (filed 10 months after the incident) and motivated by knowledge of a 2018 Will favoring Respondent No. 12.
  • The SIT’s 639-page ‘B’ report found no evidence against the appellants, and CBI investigation was unwarranted.
  • Appellants, including an elderly father and brother of the deceased, were wrongly implicated.
• Respondents (via Mukul Rohatgi, Dushyant Dave):
  • The deceased, a confidant of a former MP, faced threats over property, executing a 2016 Will favoring Respondent No. 1. A fabricated 2018 Will surfaced posthumously, linked to Respondents 12–14.
  • The SIT investigation was biased and defective, as noted by the Magistrate and High Court.
  • The appellants’ prior challenge to the FIR (Criminal Petition No. 2642/2020) was withdrawn, barring further contest.
  • CBI investigation was necessary for a fair probe given the case’s complexity and allegations of forgery.

Decision

The Supreme Court dismissed the appeals, affirming the High Court’s order for CBI investigation. Key findings:

1. FIR Registration: The appellants’ challenge to the FIR was barred, as their earlier Section 482 Cr.P.C. petition was withdrawn on 09.12.2020, making the FIR final (Criminal Petition No. 2642/2020).
2. CBI Investigation: The High Court’s directive was upheld, as Constitutional Courts have extraordinary powers to order CBI probes in exceptional cases to ensure credibility and justice (Vinay Tyagi v. Irshad Ali, (2013) 5 SCC 762; Pooja Pal v. Union of India, (2016) 3 SCC 135). The deceased’s mysterious death, conflicting Wills (2016 vs. 2018), and SIT’s defective investigation justified CBI involvement.
3. Rights of Accused: Prospective accused have no right to be heard at the investigation stage (Union of India v. W.N. Chadha, (1993) Supp (4) SCC 260).
4. Directions: CBI to complete investigation within eight months, with Karnataka Police to transfer case papers within 15 days and assist CBI. Chargesheet, if filed, to be submitted to the jurisdictional CBI Court in Karnataka.

Ratio Decidendi

• Constitutional Courts may direct CBI investigation sparingly in exceptional circumstances to ensure fair and credible probes, particularly when local investigations are inadequate.
• Withdrawal of a challenge to FIR registration precludes subsequent contests on the same issue.
• Prospective accused lack locus standi to challenge investigation directions at the preliminary stage.

Obiter Dicta

The Court refrained from detailing investigative defects to avoid influencing the CBI probe but noted the need to resolve the truth behind Raghunath’s death, given his high-profile connections and the complex property disputes.

Significance

Reinforces the judiciary’s role in ensuring impartial investigations through CBI in cases of suspected bias or incomplete probes, balancing procedural fairness with the rights of complainants and accused.

Precedents and Observations

The Supreme Court relied on several precedents to uphold the Karnataka High Court’s direction for a CBI investigation and address the appellants’ arguments. Below are the key precedents and their observations as applied in the case.

1. Vinay Tyagi v. Irshad Ali, (2013) 5 SCC 762
   • Context: Cited to establish Constitutional Courts’ power to direct CBI investigations and Magistrate’s authority under Section 173(8) Cr.P.C.
   • Observations:
     • Para 33: Magistrates can direct further investigation under Section 173(8) Cr.P.C., aided by Section 156(3). Hemant Dhasmana v. CBI (2001) 7 SCC 536 clarified courts can trigger such investigations, and such orders should not be interfered with.
     • Para 43: Superior courts under Section 482 Cr.P.C. or Article 226 can direct “further investigation,” “fresh,” “de novo,” or “reinvestigation,” sparingly and with circumspection.
     • Para 44: High Court’s powers under Section 482 do not limit Magistrate’s powers under Section 228. Courts can entrust investigations to specialized agencies like CBI when justice demands.
     • Para 45: Higher courts can order reinvestigation in exceptional cases; Magistrates can reject closure reports and direct further investigation.
   • Application: Justified High Court’s CBI directive due to SIT’s inadequate probe, ensuring credibility in a complex case.
2. Pooja Pal v. Union of India & Ors., (2016) 3 SCC 135
   • Context: Reinforced cautious exercise of Constitutional Courts’ powers to direct CBI investigations.
   • Observations:
     • Para 75: State of W.B. v. Committee for Protection of Democratic Rights (2010) 3 SCC 571 emphasized CBI directions under Articles 32/226 are exceptional, for credibility, public confidence, or fundamental rights.
     • Para 79: No absolute bar on CBI investigations post-chargesheet if exceptional facts warrant, to ensure fair probes.
     • Para 80: Reaffirmed public interest and rule of law in CBI probes, per K. Saravanan Karuppasamy (2014) 10 SCC 406 and Sudipta Lenka (2014) 11 SCC 527.
   • Application: Supported CBI probe due to mysterious death, forgery allegations, and SIT’s lapses.
3. Union of India & Anr. v. W.N. Chadha, (1993) Supp (4) SCC 260
   • Context: Addressed appellants’ claim to challenge CBI investigation as prospective accused.
   • Observations:
     • Para 92: Accused have no right to influence investigation methods. No participatory role exists until final report under Section 173(2) or process issuance under Section 204 Cr.P.C.
   • Application: Rejected appellants’ challenge, affirming prospective accused cannot interfere with investigation.
4. Satishkumar Nyalchand Shah v. State of Gujarat & Ors., (2020) 4 SCC 22
   • Context: Reinforced no right for accused to be heard during further investigation.
   • Observations:
     • Para 10: Section 173(8) Cr.P.C. does not require hearing accused before further investigation, per W.N. Chadha, Narender G. Goel (2009) 6 SCC 65, and Dinubhai Baghabhai Solanki (2014) 4 SCC 626. Sri Bhagwan Samardha (1999) 5 SCC 740 noted no such obligation exists.
   • Application: Dismissed appellants’ claim for a hearing, upholding CBI directive.
5. Mandakini Diwan & Anr. v. High Court of Chhattisgarh & Ors., (2024) SCC Online SC 2448
   • Context: Drew parallels with CBI investigation ordered despite initial suicide closure.
   • Observations:
     • Para 8: Police closed case as suicide; complaints for fair probe ignored due to accused’s influence.
     • Para 20: Awungshi Chirmayo and Bharati Tamang (2013) 15 SCC 578 supported CBI inquiry for puzzling facts or public interest. State of W.B. noted sparing use of CBI powers.
     • Para 21: CBI probe warranted for bias allegations and need for independent investigation.
   • Application: Justified CBI probe due to initial suicide closure, SIT’s inadequacy, and bias allegations.
6. Additional Precedents (Indirectly Applied):
   • Disha v. State of Gujarat (2011) 13 SCC 337, Vineet Narain (1998) 1 SCC 226, Union of India v. Sushil Kumar Modi (1996) 6 SCC 500, Rubabbuddin Sheikh (2010) 2 SCC 200: Supported CBI investigation powers in exceptional cases.

Summary of Application:

• Vinay Tyagi and Pooja Pal justified CBI probe for defective SIT investigation.
• W.N. Chadha and Satishkumar negated appellants’ right to challenge investigation.
• Mandakini Diwan paralleled initial suicide closure, supporting CBI involvement. The precedents ensured a fair, credible probe into Raghunath’s death, balancing judicial intervention and procedural fairness.

Multiple Choice Questions (MCQs)

1. What was the primary issue before the Supreme Court in 2025 INSC 556?
   a) Validity of the deceased’s Will
   b) Legality of the Magistrate’s jurisdiction to direct FIR registration
   c) Propriety of the High Court’s direction for CBI investigation
   d) Civil proceedings regarding property disputes
   Answer: c) Propriety of the High Court’s direction for CBI investigation
   Explanation: The Supreme Court primarily addressed whether the Karnataka High Court was justified in directing a CBI investigation and whether the appellants could challenge it, alongside the issue of the Magistrate’s jurisdiction.
2. Why did the Supreme Court dismiss the appellants’ challenge to the FIR registration?
   a) The FIR was registered within the statutory period
   b) The appellants withdrew their earlier petition under Section 482 Cr.P.C.
   c) The Magistrate had unlimited jurisdiction to order FIRs
   d) The CBI investigation superseded the FIR issue
   Answer: b) The appellants withdrew their earlier petition under Section 482 Cr.P.C.
   Explanation: The appellants’ prior challenge to the FIR in Criminal Petition No. 2642/2020 was withdrawn on 09.12.2020, making the FIR registration final and barring further contest.
3. Which precedent was cited to affirm that prospective accused have no right to be heard during investigation?
   a) Vinay Tyagi v. Irshad Ali
   b) Union of India v. W.N. Chadha
   c) Pooja Pal v. Union of India
   d) Mandakini Diwan v. High Court of Chhattisgarh
   Answer: b) Union of India v. W.N. Chadha
   Explanation: W.N. Chadha (1993) Supp (4) SCC 260 held that accused have no right to influence investigation until a final report or process issuance, negating the appellants’ claim to challenge the CBI probe.
4. What justified the High Court’s direction for a CBI investigation in this case?
   a) The case had international ramifications
   b) The SIT investigation was inadequate and defective
   c) The appellants were high-profile individuals
   d) The Magistrate lacked jurisdiction entirely
   Answer: b) The SIT investigation was inadequate and defective
   Explanation: The High Court and Supreme Court found the SIT’s investigation lopsided, justifying CBI involvement to ensure a fair and credible probe, as supported by precedents like Vinay Tyagi and Pooja Pal.
5. Under which legal provision was the Magistrate’s power to direct further investigation discussed?
   a) Section 156(3) Cr.P.C.
   b) Section 173(8) Cr.P.C.
   c) Section 200 Cr.P.C.
   d) Section 482 Cr.P.C.
   Answer: b) Section 173(8) Cr.P.C.
   Explanation: Vinay Tyagi v. Irshad Ali clarified that Magistrates can direct further investigation under Section 173(8) Cr.P.C. when a report is filed, as applied in rejecting the SIT’s ‘B’ report.
6. What was the time frame set by the Supreme Court for the CBI to complete its investigation?
   a) Six months
   b) Eight months
   c) Twelve months
   d) Three months
   Answer: b) Eight months
   Explanation: The Supreme Court directed the CBI to complete the investigation within eight months, extending the High Court’s six-month limit.
7. Which of the following was NOT a reason cited for directing a CBI investigation?
   a) Mysterious circumstances of K. Raghunath’s death
   b) Conflicting Wills (2016 and 2018)
   c) National security concerns
   d) Allegations of forgery and bias in SIT probe
   Answer: c) National security concerns
   Explanation: The CBI probe was justified due to the mysterious death, conflicting Wills, and SIT’s defective investigation, not national security concerns.
8. Which precedent supported the CBI investigation in a case initially closed as suicide?
   a) Pooja Pal v. Union of India
   b) Mandakini Diwan v. High Court of Chhattisgarh
   c) Satishkumar Nyalchand Shah v. State of Gujarat
   d) Vineet Narain v. Union of India
   Answer: b) Mandakini Diwan v. High Court of Chhattisgarh
   Explanation: Mandakini Diwan (2024) SCC Online SC 2448 involved a CBI probe despite an initial suicide closure, paralleling the present case’s trajectory.
9. What was the role of the Karnataka Police as per the Supreme Court’s order?
   a) To conduct a parallel investigation
   b) To transfer case papers and assist CBI
   c) To supervise the CBI investigation
   d) To file a new FIR
   Answer: b) To transfer case papers and assist CBI
   Explanation: The Court directed Karnataka Police to hand over case papers within 15 days and assist the CBI in conducting a fair investigation.
10. Which Constitutional provision was cited for the High Court’s power to direct CBI investigation?
    a) Article 32
    b) Article 226
    c) Article 136
    d) Article 142
    Answer: b) Article 226
    Explanation: The High Court’s power under Article 226 was cited, alongside Section 482 Cr.P.C., to direct CBI investigations in exceptional cases (Vinay Tyagi and Pooja Pal).

Frequently Asked Questions (FAQs)

1. What was the main dispute in Ramachandraiah & Anr. v. M. Manjula & Ors. (2025 INSC 556)?
   The dispute centered on whether the Karnataka High Court was justified in directing a CBI investigation into the alleged murder of K. Raghunath, whose death was initially treated as suicide. The appellants challenged this directive and the Magistrate’s jurisdiction to order FIR registration based on a private complaint alleging murder linked to property disputes and a contested Will.
2. Why did the Supreme Court uphold the High Court’s direction for a CBI investigation?
   The Court found the SIT’s investigation inadequate, as highlighted by the Magistrate and High Court. The mysterious circumstances of Raghunath’s death, conflicting Wills (2016 favoring his wife, 2018 favoring Respondent No. 12), and allegations of forgery justified a CBI probe to ensure credibility and justice, as supported by precedents like Vinay Tyagi v. Irshad Ali (2013) 5 SCC 762 and Pooja Pal v. Union of India (2016) 3 SCC 135.
3. Why couldn’t the appellants challenge the FIR registration in this case?
   The appellants had previously challenged the FIR in Criminal Petition No. 2642/2020 under Section 482 Cr.P.C. but withdrew it on 09.12.2020. This withdrawal made the FIR registration final and binding, barring further challenges, as noted by the Supreme Court.
4. What legal principle governs the rights of prospective accused during an investigation?
   As per Union of India v. W.N. Chadha (1993) Supp (4) SCC 260 and Satishkumar Nyalchand Shah v. State of Gujarat (2020) 4 SCC 22, prospective accused have no right to be heard or influence the investigation until a final report is filed under Section 173(2) Cr.P.C. or process is issued under Section 204 Cr.P.C. This principle negated the appellants’ claim to challenge the CBI directive.
5. Under what circumstances can a Constitutional Court direct a CBI investigation?
   Constitutional Courts (under Articles 32 or 226) can direct CBI investigations sparingly in exceptional cases, such as when local investigations are biased or inadequate, to ensure credibility, public confidence, or fundamental rights, or when the case has significant ramifications. This was established in Vinay Tyagi, Pooja Pal, and State of W.B. v. Committee for Protection of Democratic Rights (2010) 3 SCC 571.
6. What was the role of the Magistrate in this case, and why was it contested?
   The Magistrate ordered FIR registration (Crime No. 89/2020) based on a private complaint and rejected the SIT’s ‘B’ report, directing further investigation by HAL Police Station. The appellants contested the Magistrate’s jurisdiction, arguing it lacked authority to order FIRs for Sessions-triable offences post-Section 174 Cr.P.C. closure. The Supreme Court sidestepped this issue due to the appellants’ withdrawal of their FIR challenge.
7. How did the conflicting Wills contribute to the case’s complexity?
   Two Wills complicated the case: a 2016 Will favoring Respondent No. 1 (Raghunath’s wife) and a 2018 Will, allegedly fabricated and registered posthumously, favoring Respondent No. 12. Allegations of forgery, supported by a Truth Lab report and a related FIR (Crime No. 7/2021), raised doubts about the SIT’s probe, necessitating CBI investigation.
8. What was the significance of the precedent Mandakini Diwan v. High Court of Chhattisgarh in this case?
   Mandakini Diwan (2024) SCC Online SC 2448 was cited as a parallel case where CBI investigation was ordered despite an initial police closure as suicide. It supported the present case’s CBI directive, given similar allegations of bias and the need for an independent probe into Raghunath’s death.
9. What directions did the Supreme Court issue regarding the CBI investigation?
   The Court directed the CBI to complete the investigation within eight months, with Karnataka Police to transfer case papers within 15 days and provide assistance. If a chargesheet is filed, it must be submitted to the jurisdictional CBI Court in Karnataka.
10. What broader legal implication does this case have for criminal investigations in India?
    The case reinforces the judiciary’s role in ensuring fair and credible investigations through specialized agencies like CBI when local probes are deficient. It underscores the sparing use of such powers, the finality of withdrawn legal challenges, and the limited rights of prospective accused during investigations, balancing justice with procedural fairness.