Chhattisgarh High Court
Criminal Procedure and EvidenceCriminal Law

No specific directions warranted during ongoing investigation; the Investigating Officer must independently assess all evidence according to law.

ANKITA PRADHAN vs THE STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: September 15, 20262 MIN READSOURCE JUDGMENT
No specific directions warranted during ongoing investigation; the Investigating Officer must independently assess all evidence according to law.. ANKITA PRADHAN vs THE STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner alleged that influential members of her community had prohibited her from enjoying the social status and privileges of the community because she had solemnized an inter-caste marriage on 02.03.2026, evidenced by a marriage certificate dated 08.04.2026.

Source reference: para. 1

Pursuant to her complaint dated 04.08.2026, FIR No. 393/2026 was registered at Police Station Basna, District Mahasamund, for offences under Sections 308(2), 351(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

Source reference: para. 2

The petitioner contended that the private respondents’ names had not been included in the FIR and that electronic records submitted to the Investigating Officer had not been properly considered.

Source reference: paras. 2, 5

The State submitted that the investigation was at an initial stage and was being conducted in accordance with law.

Source reference: para. 3
02

Issues

Whether the High Court should direct the police authorities to include the private respondents’ names in the FIR during the pendency of the investigation.

Source reference: paras. 2, 5–6

Whether the Investigating Officer should be specifically directed to consider the electronic records and other material produced by the petitioner during investigation.

Source reference: paras. 2–3, 6

Whether any further specific direction was warranted when investigation pursuant to FIR No. 393/2026 was already in progress.

Source reference: para. 6
03

Law Applied

The Court applied Sections 308(2), 351(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023, which formed the penal basis of the registered FIR.

Source reference: para. 5

While investigation is pending, the Investigating Officer must independently examine the complaint, electronic records, and all other evidence or material collected, determine the involvement of persons in accordance with law, and complete the investigation without being influenced by judicial observations on the merits.

Source reference: para. 6
04

Reasoning

The Court noted that the FIR had already been registered for the alleged offences, although it did not name all persons allegedly involved.

Source reference: para. 5

Since the investigation was at a nascent stage, the Court considered it inappropriate to direct the police at that stage to add particular individuals as accused or to dictate the manner in which the electronic records should be evaluated.

Source reference: para. 6

Instead, it required the Investigating Officer to independently consider the petitioner’s allegations, electronic records, and the entire material collected during investigation in accordance with law.

Source reference: paras. 3, 6

The Court expressly clarified that it had not examined the factual merits of the allegations.

Source reference: para. 6
05

Holding

The Court declined to issue any specific direction requiring inclusion of the private respondents’ names in the FIR or prescribing the treatment of the electronic records.

The petition was disposed of with the expectation that the Investigating Officer would conduct an independent and lawful investigation, consider all relevant evidence and material, and conclude the investigation in accordance with law, uninfluenced by any observation in the order.

Source reference: paras. 6–7
06

Acts & Sections Cited

3 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nyaya Sanhita, 20233

Chhattisgarh High Court

Original Court PDF

ANKITA PRADHANvsTHE STATE OF CHHATTISGARH

Chhattisgarh High Court · September 15, 2026

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