Manipur High CourtCriminal Procedure and EvidenceCriminal Law

Mandatory Day-to-Day Trial for Scheduled Offences Under NIA Act Sustains Precedence Over Other Pending Matters

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 for Scheduled Offences Under NIA Act Sustains Precedence Over Other Pending Matters. 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

1. Whether the prayers for investigation and arrest in the PIL have been sufficiently addressed by the NIA's progress and the filing of the chargesheet.

The court held

The High Court disposed of the PIL, holding that the prayers of the petitioners had been addressed.

It also directed

The Court directed the Special Court to adhere to the day-to-day trial mandate under the NIA Act and requested the completion of the charge hearing and trial as expeditiously as possible.

Rights were reserved for the petitioners to approach the Court again if new issues arise.

The miscellaneous application filed by the NIA was closed as infructuous following the filing of the chargesheet.

01Facts

This Public Interest Litigation (PIL) was filed following an incident on 11.11.2024 in Jakrodhor Karong village, Jiribam District, where eight civilians (including women and children) were killed or abducted and killed, and property was set ablaze.

p. 3 · ¶ 3

The petitioners sought directions for the arrest of culprits, a time-bound investigation, and compensation for the victims' families.

pp. 3-4 · ¶ 4

During proceedings, it was noted that the National Investigation Agency (NIA) had taken over the case (Special Trial Case No. 4 of 2026), arrested three accused, and filed a chargesheet on 23.01.2026.

p. 4 · ¶ 5

The State also accorded administrative approval for ex-gratia compensation of Rs. 10 lakhs to the next of kin (NoK) for each deceased.

p. 5 · ¶ 8

02Issues

i.1. Whether the prayers for investigation and arrest in the PIL have been sufficiently addressed by the NIA's progress and the filing of the chargesheet.

p. 4 · ¶ 5 · p. 8 · ¶ 14

ii.2. Whether the trial of the case should be expedited and prioritized given the nature of the offenses and the status of the Special Court.

p. 7 · ¶ 11-12

iii.3. Whether the claim for compensation for the victims' families has been reaching the intended beneficiaries.

p. 5 · ¶ 9

03Law Applied

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

p. 7 · ¶ 12

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

pp. 6-7 · ¶ 10

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 analyzed the procedural progress of the criminal case, noting that since the chargesheet was filed and relevant papers were furnished to the accused, the matter was ready for charge hearing.

p. 5 · ¶ 7

The Court observed that the "Special Judge, NIA Special Court-I" was not a dedicated NIA court but a designated District and Sessions Court with a heavy pendency of 158 cases.

p. 7 · ¶ 11

Consequently, the Court invoked the statutory mandate of Section 19 of the NIA Act to ensure that this specific trial receives priority status.

p. 7 · ¶ 12

Regarding compensation, the Court noted the State’s submission that funds were sanctioned and disbursement was underway, except in cases of rival claims among survivors.

p. 6 · ¶ 9

The Court concluded that the primary grievances of the petitioners—investigation, arrest, and compensation—had been largely addressed by the respondents' actions.

p. 8 · ¶ 14

05Holding

The High Court disposed of the PIL, holding that the prayers of the petitioners had been addressed.

p. 8 · ¶ 14, 16

The Court directed the Special Court to adhere to the day-to-day trial mandate under the NIA Act and requested the completion of the charge hearing and trial as expeditiously as possible.

p. 8 · ¶ 13

Rights were reserved for the petitioners to approach the Court again if new issues arise.

p. 8 · ¶ 14

The miscellaneous application filed by the NIA was closed as infructuous following the filing of the chargesheet.

p. 8 · ¶ 15
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]

Manipur High Court

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