High Court declines parallel adjudication of disputed police misconduct allegations pending before the competent territorial forum.

The petitioner, married to respondent No. 5 on 06.02.2022, alleged that matrimonial disputes led to registration of FIR No. 305/2025 under Section 85 of the Bharatiya Nyaya Sanhita, 2023 and Section 4 of the Dowry Prohibition Act.

He stated that the High Court of Chhattisgarh granted him interim protection from arrest and further proceedings on 19.12.2025.

Thereafter, he alleged that police officials detained him, forcibly accessed data from his mobile phone, threatened him, and, on 23.03.2026, apprehended him from the District Court premises at Satna, Madhya Pradesh.

He further alleged that he was handcuffed, taken through Rewa to Champa, subjected to ill-treatment, and produced before the competent Court on 26.03.2026, where he was granted bail.

The petitioner sought, under Article 226 of the Constitution, directions for registration of an FIR against the police officials, an independent investigation by an SIT or other agency, departmental proceedings, and compensation for alleged violations of Articles 14, 21 and 22.

The State opposed the petition on the grounds that the allegations involved disputed questions of fact and that the principal criminal proceedings and allegations concerned Crime No. 37/2026 registered in Chhattisgarh.

The petitioner had also approached the High Court of Chhattisgarh in Writ Petition (Cr.) No. 259/2026 concerning the same incident, in which notice had been issued to respondent No. 4.

Whether this Court should exercise its writ jurisdiction in relation to Crime No. 37/2026 and the conduct of police officials of Chhattisgarh when substantially overlapping proceedings were already pending before the High Court of Chhattisgarh?

Whether the allegations of illegal inter-State arrest, handcuffing, custodial ill-treatment, unlawful detention, threats, and compelled access to mobile-phone data warranted a direction for registration of an FIR, an independent investigation, or other relief under Article 226?

Whether the petitioner was entitled to compensation for alleged violations of his fundamental rights under Articles 14, 21 and 22 of the Constitution?

The Court applied Article 226 of the Constitution, recognising that writ relief is discretionary and may ordinarily be declined where the claim involves seriously disputed questions of fact requiring evidentiary investigation.

It applied the principle of territorial jurisdiction, holding that challenges concerning an FIR registered in Chhattisgarh and the principal conduct of Chhattisgarh police authorities are appropriately considered by the competent constitutional Court in that State.

The Court also relied on Prem Shankar Shukla v. Delhi Administration, (1980) 3 SCC 526, which establishes that handcuffing is not to be undertaken routinely and is permissible only in exceptional circumstances, with appropriate justification.

The Court further recognised that compensation for constitutional violations ordinarily requires an established factual foundation demonstrating illegal detention, custodial torture, or other proven infringement of fundamental rights.

The Court held that the principal challenge concerned Crime No. 37/2026, registered in Chhattisgarh, and the actions of police officials belonging to that State; therefore, the High Court of Chhattisgarh was the appropriate forum, particularly because the petitioner had already initiated substantially overlapping proceedings there.

Although the allegations of handcuffing, custodial torture, illegal confinement, threats, and compelled disclosure of the mobile-phone password were serious, the Court found that their truth could not be conclusively determined from pleadings, photographs, complaints, and order-sheets alone.

Applying the rule in Prem Shankar Shukla, the Court observed that whether handcuffing occurred, whether exceptional circumstances existed, and whether reasons were recorded were all factual matters requiring proper inquiry.

In the absence of an undisputed violation established on the record, the Court declined to direct registration of an FIR, constitution of an SIT, disciplinary action, or payment of compensation.

The Court declined to direct registration of an FIR, an SIT or independent investigation, departmental proceedings, or compensation at that stage.

The petitioner was granted liberty to pursue his complaints and other remedies before the competent authorities and forums, including the High Court of Chhattisgarh.

The Court expressly clarified that it had not ruled on the legality of Crime No. 37/2026, the merits of the criminal allegations, or the truth of the petitioner’s allegations against the police officials; all such questions were left open for determination by the competent Court or authority.