Manipur High CourtCriminal Procedure and EvidenceHuman Rights Law

Mandatory Day-to-Day Trial and Precedence of NIA Cases Over Other Pending Judicial Proceedings

Shri Soram Tekendrajit & Anr. v. The Union of India & Ors. [PIL No. 18 of 2024 with MC(PIL) No. 28 of 2025]

Mandatory Day-to-Day Trial and Precedence of NIA Cases Over Other Pending Judicial Proceedings. Shri Soram Tekendrajit & Anr. v. The Union of India & Ors. [PIL No. 18 of 2024 with MC(PIL) No. 28 of 2025]. Manipur High Court. LawLens
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In brief

The question

Whether the prayers for investigation, arrest, and compensation have been substantially rendered infructuous by the actions already taken by the respondents.

The court held

The High Court disposed of the PIL, holding that the petitioners' grievances had been largely addressed.

It also directed

The Court directed the Special Judge (NIA Special Court-I) to adhere to the day-to-day trial mandate of Section 19 of the NIA Act and to conclude the trial and return a verdict as expeditiously as possible.

Rights were reserved for the petitioners to approach the Court again should new circumstances arise.

The miscellaneous application by the NIA was closed as not pressed.

01Facts

This Public Interest Litigation (PIL) arose from an incident on November 11, 2024, in Jakrodhor Karong village, Jiribam District, where eight civilians (including women and infants) were killed or abducted and killed, and property was set ablaze.

p. 3, para 3

The Petitioners sought directions for the arrest of the culprits, timely completion of the investigation, and payment of compensation to the victims' families.

p. 4, para 4

Procedurally, the case was transferred to the National Investigation Agency (NIA) and registered as Special Trial (NIA) Case No. 4 of 2026.

p. 4, para 5

By the time of the hearing, three accused had been arrested, a chargesheet was filed on January 23, 2026, and the State had accorded administrative approval for compensation of Rs. 10 lakhs to the next of kin of each deceased.

p. 4, para 5 · p. 5, para 8

02Issues

i.Whether the prayers for investigation, arrest, and compensation have been substantially rendered infructuous by the actions already taken by the respondents.

p. 8, para 14

ii.Whether the Special Court (NIA Special Court-I) should be directed to prioritize the trial on a day-to-day basis under the mandates of the NIA Act.

p. 7, para 12

03Law Applied

The Court applied Section 19 of the National Investigation Agency Act, 2008, which mandates that trials be conducted on a day-to-day basis and take precedence over other trials.

p. 7, para 12

It also referenced Section 193(9) of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 173(8) CrPC), regarding the power of the agency to conduct further investigation even after filing a chargesheet.

pp. 6-7, para 10

Furthermore, the court considered the State and Central ex-gratia schemes for victim compensation.

p. 6, para 9

Provisions in the judgment · 3 · Linked ones open on LawLens

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 193

Code of Criminal Procedure, 1973 Section 173

National Investigation Agency Act, 2008 Section 19

04Reasoning

The Court observed that the primary reliefs sought by the petitioners—investigation and compensation—had been effectively addressed.

The NIA had already filed the chargesheet and was continuing further investigation under Section 193(9) of BNSS to secure remaining culprits.

p. 7, para 10

Regarding compensation, the Court noted that the State had sanctioned Rs. 80 lakhs and commenced disbursement.

pp. 5-6, paras 8-9

A critical concern was the trial's pace, as the designated Special Court was not an exclusive NIA court and carried a significant backlog of civil and criminal cases.

p. 7, para 11

To mitigate this, the Court invoked Section 19 of the NIA Act to ensure the trial receives statutory precedence and is conducted daily.

p. 7, para 12

As the chargesheet had been filed, the NIA’s miscellaneous application (MC No. 28 of 2025) was deemed infructuous by the NIA's own counsel.

p. 8, para 15

05Holding

The High Court disposed of the PIL, holding that the petitioners' grievances had been largely addressed.

p. 8, para 14

The Court directed the Special Judge (NIA Special Court-I) to adhere to the day-to-day trial mandate of Section 19 of the NIA Act and to conclude the trial and return a verdict as expeditiously as possible.

pp. 7-8, paras 12-13

Rights were reserved for the petitioners to approach the Court again should new circumstances arise.

p. 8, para 14

The miscellaneous application by the NIA was closed as not pressed.

pp. 8-9, paras 15-16
Manipur High Court

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Shri Soram Tekendrajit & Anr. v. The Union of India & Ors. [PIL No. 18 of 2024 with MC(PIL) No. 28 of 2025]

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