Writ jurisdiction cannot be invoked to bypass statutory remedies for FIR registration and direct CBI investigation.

The appellant, a high-ranking official with an unblemished service record, challenged a Single Judge's order directing the CBI to register an FIR and investigate her for alleged abetment of suicide.

The deceased, a liquor licensee facing statutory demand notices for outstanding dues, committed suicide in November 2025.

Following the death, the respondent (deceased’s mother) allegedly attempted to extort money from the appellant by threatening to release a video clip.

Within days of submitting electronic evidence to the local police, the respondent filed a writ petition alleging police inaction and bias.

The Single Judge allowed the petition, bypassed the local inquiry, and transferred the case to the CBI.

1. Whether the High Court, under Article 226, can bypass alternative statutory remedies to order an immediate FIR registration and CBI investigation.

2. Whether the Single Judge erred in reaching premature findings on the merits of a criminal allegation during writ proceedings.

3. Whether the writ appeal is maintainable against an order passed by a Single Judge in a matter involving criminal jurisdiction.

The court primarily applied the principle of "exhaustion of alternative remedies" under the BNSS, 2023, and the Cr.P.C.

Sakiri Vasu v. State of UP, which establishes that grievances regarding non-registration of FIRs should be addressed via Section 156(3) before a Magistrate rather than through writ jurisdiction.

The court also invoked the "Right to Life" under Article 21 from Common Cause v. Union of India, asserting that individuals cannot be hounded by agencies without a prima facie establishment of an offence.

The doctrine of sublato fundamento cadit opus from State of Punjab v. Davinder Pal Singh Bhullar, meaning if the initial action is illegal, all subsequent proceedings fall through.

The Division Bench found that the Single Judge's directions were not in consonance with Sections 154 and 156 of the Cr.P.C. (or Section 194 of the BNSS).

The court observed that the respondent’s writ petition was filed prematurely—only five days after submitting evidence to the police—denying the local authorities sufficient time to conduct a preliminary inquiry.

The court critiqued the Single Judge for relying on unverified electronic material and making definitive observations that prejudiced the appellant's right to a fair investigation.

The court held that the respondent had failed to utilize the hierarchical statutory remedies available through superior police officers or the Magistrate.

Regarding maintainability, the court distinguished this case from others by noting that the writ sought a direct mandate for FIR registration under Article 226, making the appeal viable.

The court allowed the appeal, quashed the Single Judge’s order, and set aside the FIR registered by the CBI.

The respondent was directed to follow the necessary procedures under the BNS and BNSS if they wished to seek further legal recourse, with the caveat that authorities must decide the matter independently without being influenced by previous observations.