Saturday, 25 March 2023

Can a magistrate automatically stop the investigation in a summons case on the expiry of six months, as per S 167(5) of the CRPC?

Under Section 167 (5) of the Code of Criminal Procedure, in any case triable by a Magistrate as a summons-case, if the investigation is not concluded within a period of six months from the date on which the accused was arrested, the Magistrate shall make an order stopping further investigation into the offence unless the officer making the investigation satisfies the Magistrate that for special reasons and in the interests of justice the continuation of investigation beyond the period of six months is necessary. The provision unequivocally states that the Magistrate can stop investigation on contingency that the Investigating Officer has failed to satisfy the Magistrate that for special reasons and in the interests of justice the continuation of the investigation beyond the period of six months is necessary. There cannot be any automatic order without anything else on expiry of a period of six months from the date of arrest. 

 IN THE HIGH COURT AT CALCUTTA

CRIMINAL REVISIONAL JURISDICTION

APPELLATE SIDE

CRR 3168 of 2012

I.A. No. CRAN/3/2014 (Old No. CRAN/4575/2014)

Kamal Ghosh & Anr. Vs. The State of West Bengal & Anr.

Before: Hon’ble Justice Sugato Majumdar

Judgment on : 23.03.2023

The instant application is filed under Section 401 read with Section

482 of the Criminal Procedure Code challenging the impugned orders dated

24.06.2011, 19.07.2011, 17.08.2011, 17.01.2012, 24.02.2012, 26.03.2012,

26.04.2012, 28.05.212, 28.06.2012, 16.07.2012 passed by the Chief

Metropolitan Magistrate in G. R. Case No. 191 of 2011 connected to

Section – H, Bowbazar Police Station Case No. 41 dated 16.01.2011 as well

as order passed by the Metropolitan Magistrate, 3rd Court dated 17.07.2012.

The nutshell of grievances of the present Petitioner are that, firstly the

Investigating Officer was allowed time beyond a period of six months in

terms of various impugned orders passed by the Chief Metropolitan

Magistrate without conforming to the provisions of Section 167 (5) of the

Criminal Procedure Code.

Secondly, it is also the grievance of the Petitioner that the fact of the

case does not disclose commission any offence which both the Chief

Metropolitan Magistrate and the Metropolitan Magistrate, 3rd Court failed to

consider.

Thirdly that after filing of charge sheet the Chief Metropolitan

Magistrate transferred the case to the Metropolitan Magistrate, 3rd Court for

taking cognizance without taking cognizance of the offence; the Metropolitan

Magistrate, 3rd Court, however, took cognizance of the offence in terms of the

order dated 17.07.2012 offending the provision of Section 190 of the Code of

Criminal Procedure.

Mr. S. N. Arefin appearing for the Petitioners submitted that under

Section 167 (5) of the Code of Criminal Procedure there is a specific time

limit of six months to conclude investigation, from the date of arrest. This

provision is applicable to the instant case, and the Magistrate is duty bound

to make an order stopping further investigation into the offence. This is not

done by the Chief Metropolitan Magistrate. The Chief Metropolitan

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Magistrate continued to allow time in a mechanical manner. Therefore,

according to him, the proceeding should be quashed. It is argued by the

learned Counsel for the Petitioners that the Chief Metropolitan Magistrate

committed an error is not taking cognizance of the offence and transferring

the same to the Metropolitan Magistrate for taking cognizance.

It is further submitted by him that the Chief Metropolitan Magistrate

failed to consider or apply the mind to understand that no prima facie case

is made out against the Petitioners; the allegations are baseless for which

the proceeding should be quashed.

Mr. Imran Ali appearing for the State submitted that there is no

infirmity in the proceeding so far as taking cognizance under Section 190 is

concerned. According to him, the Petitioner failed to make out a proper case

in this regard. He further submitted that Section 192 of the Code of

Criminal Procedure saves taking cognizance of the offence by the Magistrate.

According to him, the application should be rejected.

I have heard rival submissions.

Under Section 167 (5) of the Code of Criminal Procedure, in any case triable by a Magistrate as a summons-case, if the investigation is not

concluded within a period of six months from the date on which the accused

was arrested, the Magistrate shall make an order stopping further

investigation into the offence unless the officer making the investigation

satisfies the Magistrate that for special reasons and in the interests of

justice the continuation of investigation beyond the period of six months is


necessary. The provision unequivocally states that the Magistrate can stop

investigation on contingency that the Investigating Officer has failed to

satisfy the Magistrate that for special reasons and in the interests of justice

the continuation of the investigation beyond the period of six months is

necessary. There cannot be any automatic order without anything else on

expiry of a period of six months from the date of arrest. The learned

Counsel for the Petitioner, at the time of hearing candidly admitted that no

step was taken or no petition was made before the Trial Court objecting to

the impugned orders extending time for investigation. The Petitioner was

silent at that time but suddenly the Petitioner woke up into the action after

filing of the charge sheet on completion of the investigation, clubbing several

actions against several courts together. Therefore, the objection regarding

extension of time at this belated stage is not sustainable.

Section 190 (1) provides that any Magistrate of First Class may take

cognizance of an offence upon receiving a) a complaint of facts which

constitutes such offence, b) upon a police report of such facts, c) upon

information received from any person other than Police Officer or upon his

own knowledge that such offence have been committed. This case squarely

falls within ambit of Section 190 (1) (b) of the Code of Criminal Procedure.

In terms of the specific provisions of the statute, any Magistrate is

empowered to take cognizance of the offence. Moreover, Section 460 (e) of

the Code provides that if any Magistrate who is not empowered by law to do

any of the following things entirely among others to take cognizance of an

offence under Clause a or Clause b of Sub-section (1) of Section 190

erroneously in good faith, proceeding shall not be set aside merely on that

ground. Therefore, even if it is assumed that there is an irregularity, the

same is saved of Section 460 (e) of the Code of Criminal Procedure.

Proceeding cannot be quashed.

So far as factual aspect of the case is concerned, consideration of

charge is yet to be done. The Petitioner can agitate before the Trial Court

that available materials do not disclose any offence. It is not that the

Petitioner is bereft of any remedy. He has remedy which he should exercise

at opportune moment, at the time of consideration of charge.

In nutshell, the instant revision application is not tenable and is

dismissed on merit. The Trial Court is to consider charge within a period of

one month from the date of receiving of this order.

The copy of this order may be sent to the Trial Court forthwith.

The instant criminal revision stands disposed of.

The instant revision is accordingly disposed of along with pending

application, if any.

(Sugato Majumdar, J.)

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