In Ranjit Singh Bath & Anr. v. Union Territory Chandigarh & Anr.<\/em> (2025), a two\u2011judge bench of the Supreme Court, comprising Justices Abhay\u202fS.\u202fOka and Ujjal\u202fBhuyan, restated a fundamental principle of criminal procedure: a complainant cannot invoke Section\u202f156(3) CrPC to order an investigation unless they first exhaust the remedies under Sections\u202f154(1) and 154(3).<\/strong> This landmark ruling not only reinforces the binding Priyanka Srivastava v. State of UP<\/em> (2015) precedent but also safeguards against abuse of judicial power, ensuring the police station remains the primary gateway for FIR registration.<\/p>\n\n\n\n The case revolves around a complaint filed by the second respondent under Section 156(3)<\/strong> of the Criminal Procedure Code, 1973 (CrPC)<\/strong>. The respondent alleged commission of offences under Sections 420 and 120-B<\/strong> of the Indian Penal Code, 1860 (IPC)<\/strong>. Acting upon this application, the Judicial Magistrate<\/strong> passed an order dated 14th June 2017<\/strong>, directing the concerned police station to register an FIR. This led to the initiation of criminal proceedings against the appellants. Aggrieved by the Magistrate’s order, the appellants approached the Punjab and Haryana High Court<\/strong> by filing a quashing petition, citing that proper procedure under Sections 154(1)<\/strong> and 154(3)<\/strong> of the CrPC had not been followed prior to seeking recourse under Section 156(3).<\/p>\n\n\n\n The appellants emphasized that the binding precedent set in Priyanka Srivastava v. State of U.P. (2015)<\/strong>\u2014which mandates compliance with Sections 154(1) and (3) before invoking Section 156(3)\u2014was ignored. They argued that there was no specific averment or document produced<\/strong> by the complainant to show that such remedies were exhausted. They also cited Babu Venkatesh v. State of Karnataka (2022)<\/strong>, which reinforced this requirement. On the other hand, the respondent contended that a complaint had been submitted to the Inspector General of Police<\/strong>, which was marked to the Economic Offences Wing in 2014. However, this action was not explicitly presented as compliance with Section 154(3), nor were sufficient supporting documents or averments made in the complaint to substantiate this procedural step. These conflicting positions formed the core of the dispute before the Supreme Court<\/strong>.<\/p>\n\n\n\nFacts of the Case<\/h2>\n\n\n\n
Laws Involved<\/h2>\n\n\n\n
\n