Courts must give informants effective notice and opportunity to file objections before accepting closure reports.

The petitioner challenged the order dated 09.02.2022 passed by the Special Judge, Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, Rewa, in Case No. 451/2022, whereby the Court accepted the police closure report and closed the proceedings arising from the petitioner’s complaint

The petitioner, who was the informant, alleged that the closure report had been accepted without effective notice or an opportunity to file a protest petition.

He also identified alleged investigative deficiencies, including failure to examine relevant witnesses, collect CCTV footage, properly investigate an allegedly forged marksheet, and adequately examine the accused Principal

The State opposed the petition and supported the impugned order

Whether the Special Judge could accept the police closure report and terminate the proceedings without first notifying the informant/complainant and providing an effective opportunity to file objections or a protest petition

Whether the order accepting the closure report was liable to be set aside and the matter remanded for fresh consideration after hearing the informant

When a police closure report is submitted, the informant or complainant has a valuable procedural right to receive notice and to place objections, including through a protest petition, before the Court forms its judicial opinion on the report

This requirement flows from natural justice and fair procedure, particularly because acceptance of a closure report terminates the criminal proceedings and directly affects the person who set the criminal law in motion

The Court relied on the principle reiterated in Reva Adivasi v. State of Madhya Pradesh & Others, W.P. No. 10310/2026, decided on 16.06.2026, that an affected complainant or victim must be afforded a meaningful opportunity to present objections before a closure report is decided

The Court also referred to the Supreme Court’s recognition of the informant’s right to be heard before acceptance of a police closure report

The record did not show that the petitioner had been effectively served with notice of the closure report or given a meaningful opportunity to file a protest petition before the Special Judge accepted it

The petitioner’s allegations concerning unexamined witnesses, non-collection of CCTV footage, inadequate investigation of the forged marksheet, and insufficient examination of the accused Principal were matters that he was entitled to place before the trial Court before the judicial opinion on the closure report was formed

The defect therefore went to the root of the decision-making process and was not a mere procedural irregularity

The High Court expressly declined to assess the merits of the allegations or the correctness of the closure report, holding that those questions should first be considered by the Special Judge after compliance with the requirements of fair procedure

The order dated 09.02.2022 was set aside, and the matter was remanded for fresh consideration of the closure report

The Special Judge was directed to serve notice on the petitioner, provide or permit inspection of the closure report and permissible accompanying material, allow reasonable time to file a protest petition or objections, and thereafter hear both the petitioner and the prosecution before deciding the matter afresh in accordance with law

The petition was accordingly allowed and disposed of, without any opinion on the merits of the allegations, investigation, evidence, or closure report