Seven Years On, Delhi HC Directs DCP To Personally Supervise Complainant’s Cheating-And-Forgery FIR Probe

The petitioner, complainant in FIR No. 154/2019, registered at P.S. Pandav Nagar under Sections 420, 468, 471 and 34 IPC, sought a direction for the DCP, East District, to review and supervise the investigation.

Her application for monitoring the investigation was pending before the Magistrate, who had issued directions concerning, among other matters, collection of specimen signatures, obtaining bank records, examination of bank witnesses, and investigation of the alleged bank official’s role.

In an order dated 17 February 2026, the Magistrate requested the ACP to review the file and required reports addressing the delay, bank investigation, recovery and specimen signatures.

The petitioner approached the High Court alleging that the Magistrate’s directions were not being complied with.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, invoked with Article 226 of the Constitution, was the stated basis for the petition.

Under the principle in Sakiri Vasu v. State of U.P., (2008) 2 SCC 409, a Magistrate may direct and monitor a proper investigation where the police have failed to investigate, or have not investigated satisfactorily.

The Court also referred to Robert Lalchungnunga Chongthu v. State of Bihar, 2025 SCC OnLine SC 2511, and Sahil Abdulsattar Mansuri v. Safimahamad Fafirbhai Mansuri, 2026 SCC OnLine SC 1073, in support of prompt completion of investigations and the need for constitutional courts not to remain passive in the face of prolonged, inconclusive investigations.

The Magistrate was already seized of the monitoring application and had issued detailed directions addressing investigative deficiencies; the petitioner’s grievance was that those directions were not being followed.

The High Court recognised the Magistrate’s role in monitoring the investigation under Sakiri Vasu, but considered that the FIR’s continued investigation since 2019 warranted supervisory intervention, particularly in light of the cited authorities concerning promptness and prolonged investigations.

It therefore directed oversight by the DCP while leaving the pending application for determination by the Magistrate.

It also directed the Magistrate to take up the petitioner’s application on the date fixed and pass appropriate orders.

The petitioner was granted liberty to return to the High Court if the directions were not complied with; the petition and pending application were disposed of.