Trial court is the appropriate forum for examining evidentiary discrepancies once investigation concludes and charge-sheet is filed.

The petitioner filed a writ petition under Article 226 of the Constitution alleging that medical facts regarding the death of his uncle, Radhakrishna, were suppressed or incorrectly recorded in the post-mortem report by respondent No. 5

The incident involved an assault on 11.01.2025 by villagers armed with weapons following a dispute over a tractor passage

While the Naksha Panchanama recorded multiple injuries, the post-mortem report noted only two minor injuries and cited "accidental" cardio-respiratory failure

A court-ordered enquiry by the Superintendent of Police, Shivpuri, and a subsequent forensic expert opinion confirmed that death resulted from multiple internal injuries missed in the original report

Despite these findings, the petitioner’s representation for departmental action against erring officials remained undecided

Notably, the police investigation had already concluded, and a charge-sheet had been filed in the Sessions Court

1. Whether the High Court should exercise its extraordinary jurisdiction to direct departmental action and rectify investigative discrepancies when the criminal trial is already pending before a Sessions Court

2. Whether the petitioner has an alternative efficacious remedy to address medical evidentiary inconsistencies within the framework of the ongoing trial

The Court applied the principle of judicial restraint in criminal matters where an alternative remedy exists.

It relied on Sakiri Vasu v. State of Uttar Pradesh (2008) 2 SCC 409, which held that High Courts should refrain from exercising extraordinary jurisdiction when an effective remedy is available before a criminal court

It further cited Divine Retreat Centre v. State of Kerala (2008) 3 SCC 542, establishing that parties must raise grievances before the court seized of the matter

Finally, the court applied CBI v. Rajesh Gandhi (1997) 1 SCC 413, which stipulates that once an investigation is complete and the charge-sheet is filed, the High Court should not ordinarily interfere with the manner of investigation

The Court reasoned that since the investigation had culminated in a charge-sheet and the matter was at the trial stage, the Sessions Court is the appropriate forum to evaluate evidentiary discrepancies

The Court observed that the petitioner’s grievances regarding the conflict between the Naksha Panchanama, the forensic enquiry report, and the post-mortem report are matters of "appreciation of medical evidence"

Under the legal framework, the trial court possesses the authority to examine medical experts, consider the enquiry report, and determine the credibility of the evidence

Consequently, the High Court determined that exercising jurisdiction under Article 226 or Section 482 of Cr.P.C. to scrutinize the validity of evidence at this stage would be inappropriate

The holding clarifies that the Sessions Court is fully empowered to consider the enquiry report and medical discrepancies upon the filing of an appropriate application

The trial court was directed to pass a reasoned and speaking order on such an application in accordance with law

The High Court expressed no opinion on the merits of the allegations