LexRAMACHANDRAIAH & ANR. versus M. MANJULA & ORS.
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[2025] 4 S.C.R. 1522 : 2025 INSC 556 Ramachandraiah & Anr. v. M. Manjula & Ors. (Criminal Appeal No. 2179 of 2025) 23 April 2025 [Dipankar Datta and Prashant Kumar Mishra,* JJ.] Issue for Consideration Whether in the facts and circumstances of the case, the High Court was justified in directing for investigation by the CBI. Headnotes† Investigation – CBI investigation – Direction by High Court – Deceased was a close confidant of one DKA, a Member of Parliament – He owned many immovable properties – After the death of DKA, tiff between the deceased and the children of DKA (one of the appellants) as regards those properties – Deceased died under mysterious circumstances – FIR registered inter alia against appellants for murder of the deceased – SIT constituted – Magistrate not satisfied with the investigation conducted by SIT, directed further investigation by Police – Challenged by wife and son of the deceased, High Court directed CBI to conduct further investigation – Correctness: Held: High Court rightly directed the investigation by CBI – Once an FIR is registered and investigation has taken place, direction for an investigation by the CBI is not open to challenge by the prospective suspect or accused – The matter for entrusting investigation to a particular agency is basically at the discretion of the Court – On facts, the truth surrounding the death of the deceased needs to be settled after a complete and fair investigation by CBI – Deceased was closely associated with DKA, an MP and Chairman of Temple Sri Venkateswara Swamy Temple (Tirumala Tirupathi Devasthanam) – Deceased was a successful realtor and had huge assets in and around Bangalore – His mysterious death was preceded by execution of two different Wills, one in favour of his wife-respondent no.1 and the other in favour of respondent No.12 which was registered after his controversial death – There are also civil proceedings relating to mutation and declaration of * Author [2025] 4 S.C.R. 1523 Ramachandraiah & Anr. v. M. Manjula & Ors. title as well as the allegations concerning forgery of stamp papers – The Magistrate while directing further investigation and the High Court, under the impugned order, highlighted the glaring defects in the investigation – Order of the High Court affirmed. [Paras 16, 18] Constitutional Courts – Power to direct CBI investigation – To be exercised sparingly and in exceptional circumstances: Held: High Court or the Supreme Court being Constitutional Court is vested with extra-ordinary power to direct CBI investigation depending upon the facts and circumstances of the case – The Constitutional Courts are expectantly and reverently entrusted with the duty to serve justice being a sovereign and premiere constitutional institution – Power to direct for CBI investigation is to be exercised sparingly and in exceptional circumstances, but, when the facts so demand, it is extremely necessary to exercise the said power to provide credibility and instil confidence in order to do complete justice and for enforcing the fundamental rights. [Para 11] Case Law Cited Union of India & Anr. v. W.N. Chadha [1992] Supp. 3 SCR 594 : (1993) Supp. 4 SCC 260; Satishkumar Nyalchand Shah v. State of Gujarat & Ors. [2020] 3 SCR 1106 : (2020) 4 SCC 22 – relied on. Vinay Tyagi v. Irshad Ali [2012] 13 SCR 1005 : (2013) 5 SCC 762; Pooja Pal v. Union of India & Ors. [2016] 11 SCR 560 : (2016) 3 SCC 135; Mandakini Diwan & Anr. v. High Court of Chhattisgarh & Ors. [2024] 9 SCR 86 : 2024 SCC online SC 2448 – referred to. List of Acts Penal Code, 1860; Code of Criminal Procedure, 1973. List of Keywords CBI investigation; Direction by High Court for CBI investigation; Prospective suspect or accused; Writ of mandamus; Further investigation; Mysterious death; D.K. Adikeshavalu, Member of Parliament; Close aid; Fabricated Will; Posthumously registered; Private Complaint; Special Investigation Team (SIT) Report; Investigation lopsided; Constitutional Courts; Extra-ordinary power to direct CBI investigation; Prospective Accused; Right to defend at preliminary stage; No right to be heard at stage of registration of FIR. 1524 [2025] 4 S.C.R. Supreme Court Reports Case Arising From CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No. 2179 of 2025 From the Judgment and Order dated 03.09.2022 of the High Court of Karnataka at Bengaluru in WP No. 7784 of 2022 With Criminal Appeal No. 2180 of 2025 Appearances for Par
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