Vivek Joshi vs State Of Rajasthan on 24 July, 2026

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    Vivek Joshi vs State Of Rajasthan on 24 July, 2026

                                                                                     SLP (Crl.) No.12827/2026
    
         ITEM NO.25                               COURT NO.5                       SECTION II-D
    
                                      S U P R E M E C O U R T O F            I N D I A
                                              RECORD OF PROCEEDINGS
    
                 Petition(s) for Special Leave to Appeal (Crl.) No(s).12827/2026
    
         [Arising out of impugned final judgment and order dated 12-05-2026
         in SBCRMP No. 8757/2024 passed by the High Court of Judicature for
         Rajasthan at Jaipur]
    
         VIVEK JOSHI                                                                Petitioner(s)
    
                                                              VERSUS
    
         STATE OF RAJASTHAN & ORS.                                                  Respondent(s)
    
         FOR ADMISSION
         IA No. 203042/2026 - EXEMPTION FROM FILING O.T.
    
         Date : 24-07-2026 This matter was called on for hearing today.
    
         CORAM :                 HON'BLE MR. JUSTICE J.B. PARDIWALA
                                 HON'BLE MR. JUSTICE K. VINOD CHANDRAN
    
         For Petitioner(s) :Mr. Anand Mishra, AOR
    
    
         For Respondent(s) :
    
    
                                 UPON hearing the counsel the Court made the following
                                                    O R D E R
    

    1. The petitioner is aggrieved with the impugned order of the

    High Court which directed a chargesheet to be filed against the

    SPONSORED

    absconding accused for offences under Sections 406 and 420 of the

    Indian Penal Code, 1860 (IPC) before the jurisdictional Court which

    was also directed to proceed under Section 299 of the Code of

    Criminal Procedure, 1973 (Cr.PC). The petitioner’s contention is
    Signature Not Verified

    Digitally signed by
    that though initially the FIR was lodged under Sections 406 and 420
    HARPREET KAUR
    Date: 2026.07.27
    16:14:17 IST
    Reason:

    IPC, he had omitted to include Section 66D of the Information and

    Technology Act, 2000 (IT Act) which is also attracted on the
    SLP (Crl.) No.12827/2026

    allegations levelled. By an application, the same was sought to be

    included which was allowed by the Judicial Magistrate No.7, Jaipur

    Metropolitan-II. The omission to mention Section 66D in the

    impugned order prejudices the petitioner, is the contention.

    2. On a reading of the order of the High Court, it is very

    evident that the High Court interacted with the Investigating

    Officer (I.O.) who was present in person. It is on the

    Investigation Officer’s submissions that she has prima facie found

    the allegations under Sections 406 and 420 of the IPC, that the

    directions were issued.

    3. In fact, ideally the High Court ought to have only directed

    the investigation to be concluded and chargesheet to be filed.

    Abhinandan Jha v. Dinesh Mishra1, held that the formation of an

    opinion, as to whether or not there is a case to place the accused

    on trial, is exclusively that of the officer in-charge of the

    investigation.

    4. In any event, we see that the impugned order only directs the

    chargesheet to be filed under Sections 406 and 420 IPC, on the

    submissions made by the I.O. before Court that such offences have

    been made out. However, the cited decision also held that when a

    chargesheet is filed before the Magistrate, it is the judicial

    discretion of the Magistrate to take cognizance. Ram Naresh Prasad

    v. State of Jharkhand & Ors.2 held that even when a “Closure

    Report”, finding no case made out is filed, the Court, though

    cannot direct a chargesheet to be filed but could always take

    1 1967 SCC OnLine SC 107
    2 (2009) 11 SCC 299
    SLP (Crl.) No.12827/2026

    cognizance on the basis of the material in the report or direct

    further investigation.

    5. H.S. Bains v. State (Union Territory of Chandigarh)3 and

    Ramswarup Soni v. State of Madhya Pradesh4, reiterated that when a

    Closure Report is filed, finding no offence made out, the Court has

    three options; (i) to accept the same and close the proceedings or

    (ii) take cognizance of the matter on the materials in the report

    or (iii) direct further investigation.

    6. Hence, even if the chargesheet is filed only under Section 406

    and 420 IPC, it would be open for the Magistrate to decide whether

    Section 66D has to be included or not, at the time of taking

    cognizance. The petitioner would be entitled to urge his

    contentions at that point.

    7. Insofar as the direction to file the chargesheet under Section

    299; the provision speaks of recording of evidence in the absence

    of accused. It is in the circumstances of the accused having

    absconded that the High Court made mention of Section 299, only

    reminding the Magistrate’s Court that when an accused is

    absconding, if there is no chance of the accused being apprehended,

    then the evidence should be recorded which would be used against

    the accused on his apprehension later, if the witnesses are not

    available or cannot be procured at that point of time.

    8. We find no reason to interfere with the order passed by the

    High Court but only clarify that the Magistrate would have the

    discretion to consider whether cognizance is to be taken under

    3 (1980) 4 SCC 631
    4 2019 SCC OnLine 1335
    SLP (Crl.) No.12827/2026

    Section 66D of the IT Act at the time the same is considered by the

    Magistrate. So far as Section 299, it is the call of the Magistrate

    to decide whether the facts of the case require the invocation of

    Section 299 of Cr.PC.

    9. With the above reservations, the Special Leave Petition is

    disposed of.

    10. Pending application(s), if any, shall stand disposed of.

     (HARPREET KAUR)                                 (POOJA SHARMA)
    COURT MASTER (SH)                              COURT MASTER (NSH)
    



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