Jitendra Pratap Singh vs. Union of India & Ors.
Background
The petitioner, an IRS officer who was himself an accused in a 2015 CBI case over an investigation he conducted while posted with the Enforcement Directorate, filed complaints with the CVC alleging that named officials had interfered with his investigation. The CVC forwarded the complaints to the CBI, which conducted a "verification" (rather than registering a fresh FIR) and ultimately found no actionable material against the accused officials. The petitioner asked the High Court to direct the CBI to register a cross-FIR or fresh case.
Decision Breakdown
The Court dismissed the petition, holding that the CBI's complaints were not rejected outright: they were verified pursuant to the CVC's direction, and a report was submitted. The petitioner's grievance was essentially about the adequacy of that verification and its conclusions, which is not, by itself, a ground for a court to order a fresh FIR under its extraordinary writ/inherent jurisdiction. The Court noted the petitioner's own criminal case was pending separately and he could raise his allegations as defences there.
Lesson Learnt
Courts will not order registration of a fresh FIR merely because a complainant is dissatisfied with how an investigating agency evaluated his complaint; the agency's verification process, once genuinely undertaken, is not ordinarily second-guessed by writ courts.