Reason is the Life of Law: Calcutta High Court Quashes Magistrate's Reinvestigation Order for Lack of Reasoning

Calcutta High Court quashed an order passed by the Chief Judicial Magistrate, Howrah, which had directed reinvestigation into allegations under the Indian Penal Code, Copyright Act, and Trademark Act. Justice Shampa Dutt (Paul) emphasized the necessity for judicial orders to include sound reasoning, especially when impacting fundamental rights of the accused.

The case involved allegations under Sections 420 (cheating) and 405 (criminal breach of trust) of the IPC, along with violations of the Copyright Act and Trademark Act. The dispute arose from Domjur Police Station Case No. 551/2020, where the complainant had objected to the filing of a final report treating the case as a civil matter. The Magistrate had, on August 3, 2022, ordered a fresh investigation with a new Investigating Officer, citing dissatisfaction with the earlier probe.

However, the High Court criticized the Magistrate’s order for lacking cogent reasoning. Citing the principle that "reason is the life of law," Justice Dutt observed, “There is hardly any statutory provision under the law requiring reasons in judgments, but it stands unequivocally settled by various judgments that courts and tribunals are required to pass reasoned judgments.”

The judgment referenced the Supreme Court’s directive in Chandra Babu alias Moses v. State (2015), which mandates caution and proper judicial oversight when ordering further investigations. The Court noted, “Failure to give reasons amounts to a denial of justice. Reasons ensure public confidence and provide the litigant with a legitimate expectation of fairness.”

Further, the High Court highlighted that the principles of natural justice were compromised as the Magistrate did not adequately evaluate submissions or the investigative record. This oversight was deemed a significant abuse of judicial discretion, particularly as the final report in favor of the accused had already been filed.

The High Court set aside the Magistrate's order, emphasizing that any reinvestigation must not be arbitrary but should follow established legal principles. It directed the trial court to reconsider the complainant's objections through a fresh hearing, ensuring a reasoned decision within two months.

Justice Dutt remarked, “The trial court shall hear the ‘narazi petition’ afresh, giving all parties a fair opportunity to be heard. A reasoned order must be passed in accordance with the law.”

The judgment underscores the judiciary's duty to balance investigative fairness with procedural safeguards, highlighting that procedural errors must not undermine the accused's rights or the integrity of judicial processes.

Date of Decision: 28/11/2024