Supreme Court Clarifies Guidelines for CBI Investigations in Routine Cases
Supreme Court's Stance on CBI Investigations
New Delhi: The Supreme Court has emphasized that courts should not routinely mandate CBI investigations merely based on allegations against local police, but should reserve such actions for exceptional circumstances.
This clarification came from a bench comprising Justices Sudhanshu Dhulia and K. Vinod Chandran while reviewing a special leave petition from an accused challenging a Punjab and Haryana High Court decision that transferred the investigation from Haryana Police to the CBI at the request of the complainant.
The complainant, a businessman in the pharmaceuticals sector, claimed that the accused impersonated an Inspector General of the Intelligence Bureau (IB) and coerced him into transferring ₹1.49 crore to his account, in addition to pressuring him to engage in business with the accused's associates.
Justice Dhulia's bench questioned the urgency of the complainant's appeal to the High Court for a CBI investigation under Section 482 of the CrPC, given that the FIR was filed on October 22, 2022, and the investigation was still in its early stages.
It was noted that the complainant had known the appellant since 2019 due to their business dealings, raising doubts about his claim of being unaware of the impersonation until October 2022.
The Supreme Court remarked that the Punjab and Haryana High Court should have exercised caution before intervening in the investigation, as the case did not warrant a CBI inquiry at such an early stage. The allegations were not directed at a high-ranking IPS officer but rather at someone allegedly posing as one. The court pointed out that vague allegations against Haryana Police officials were insufficient to justify a CBI investigation without substantial evidence.
The bench concluded that CBI investigations should only be initiated when there is prima facie evidence necessitating such an inquiry, rather than based on ambiguous claims.
After reviewing the case records, the Supreme Court determined that this particular case did not merit a CBI investigation and subsequently overturned the Punjab and Haryana High Court's order.