High Court declines interference in ongoing investigation absent cogent evidence of mala fides or abuse.

The petitioner, who belongs to a Scheduled Caste, alleged that Respondents 6 and 7 abused and assaulted him despite being aware of his caste status.

An FIR was registered at Police Station Gotegaon, District Narsinghpur, as FIR No. 388 of 2026 for offences under Sections 296(b), 115(2), and 351(2) of the Bharatiya Nyaya Sanhita, 2023, but not under the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (“SC/ST Act”).

The petitioner submitted representations dated 12 June 2026, 23 June 2026, and 3 July 2026 to the concerned authorities, seeking consideration of the alleged offences under the SC/ST Act and a fair investigation.

The State submitted that the FIR had already been registered, investigation was underway, and the applicability of further offences would depend upon the evidence collected during investigation.

Whether the High Court should issue a writ of mandamus directing the police and district authorities to decide the petitioner’s representations and register the offences under the SC/ST Act while the criminal investigation was ongoing.

Whether the Court should interfere with or supervise the ongoing investigation in the absence of cogent material showing mala fide conduct, suppression of evidence, or investigation under the influence of the accused.

Whether the petitioner had an alternative remedy before the competent criminal court if the investigation or charge-sheet was found to be deficient.

The Court applied the principles governing the High Court’s inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, holding that such power is wide but exceptional and must be exercised sparingly, cautiously, and only to secure the ends of justice or prevent abuse of process.

Mere dissatisfaction with the manner or progress of an investigation is insufficient for judicial interference; substantial material indicating mala fides, deliberate suppression of evidence, or improper influence is required.

Although the investigating agency must examine all allegations in accordance with law, a complainant’s membership of a Scheduled Caste does not, by itself, establish that the ingredients of an offence under the SC/ST Act are satisfied; applicability of that statute must be assessed on the allegations and evidence collected during investigation.

After filing of the charge-sheet, the competent criminal court may direct further investigation in accordance with law.

The Court found that the FIR had already been registered and the investigation was in progress.

The petitioner produced no cogent or substantive material demonstrating that the Investigating Officer was acting mala fide, suppressing material evidence, or investigating under the influence of the accused.

The Court therefore declined to determine, at the investigation stage, whether the alleged facts attracted the SC/ST Act, since doing so would require assessment of witness statements and other investigative material and would amount to a premature evaluation of evidence.

The petitioner’s dissatisfaction with the authorities’ failure to act on his representations did not justify the High Court assuming supervisory control over the investigation.

Any grievance regarding omissions or improper investigation could be raised before the competent criminal court after submission of the charge-sheet.

The Court clarified that it had expressed no opinion on the merits of the allegations, the culpability of the accused, or the applicability of the SC/ST Act.

The investigating agency was directed, in effect, to conduct the investigation objectively, fairly, and strictly in accordance with law, uninfluenced by the observations in the order.