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State of Karnataka v. T.N. Sudhakar Reddy

Criminal Appeal · 2025 INSC 229Decided 17 Feb 2025
Crl.A. No.-005001-005001 - 2024 (Arising out of SLP (Crl.) No(s). 13264 of 2024)
Justice Dipankar Datta · Justice Sandeep Mehta

Background

The respondent, a public servant with the Karnataka Power Transmission Corporation, was investigated after a source information report alleged he had accumulated assets worth about Rs. 3.81 crore: roughly 90% more than his known income. The Superintendent of Police, Karnataka Lokayukta, issued a single composite order both directing registration of an FIR against the respondent under the Prevention of Corruption Act and simultaneously authorising the investigating officer to conduct the investigation. The Karnataka High Court quashed this FIR, holding that the order improperly combined FIR registration with an investigation authorisation in a way that bypassed the mandatory preliminary-inquiry safeguards under Section 17 of the PC Act.

Decision Breakdown

The Supreme Court held that Section 17 of the PC Act governs only who may conduct an investigation and under what authorisation. It does not touch or restrict the separate, more basic duty under the CrPC to register an FIR once a cognizable offence is disclosed. A preliminary inquiry is not mandatory in every case; where a superior officer has before him a detailed, well-reasoned source information report that would lead any reasonable person to conclude a cognizable offence is disclosed, the preliminary inquiry stage can be dispensed with. Reading the PC Act and CrPC harmoniously, the Court held the Superintendent of Police was fully competent to issue one composite order both directing FIR registration and authorising the investigation, and that this had been done without any undue haste. The High Court's order quashing the FIR was set aside, and the FIR was restored for investigation to proceed.

Lesson Learnt

Police authorities are not legally barred from registering an FIR and authorising its investigation in a single order in corruption cases: a preliminary inquiry is only required where the underlying information does not already disclose a cognizable offence on a reasonable reading, not as an automatic prerequisite in every case.

Official source (sci.gov.in)View Judgment (PDF)

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