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Case Analysis Ramesh Chander & Ors vs State NCT of Delhi 2026 DHC 1390

Synopsis

This judgment, delivered by a Single Judge of the Delhi High Court, disposes of two connected matters arising from the same set of facts under the Wild Life (Protection) Act, 1972. The first is a petition by complainants (police officials) challenging the acquittal of the accused, Meetu Singh, by the Sessions Court. The second is an appeal by the State challenging the stringent directions issued by the Sessions Judge, which included ordering a disciplinary inquiry and registration of an FIR against four police officials for alleged manipulation of evidence. The High Court upheld the acquittal of the accused, finding that the Sessions Judge's doubts about the recovery were justified. However, it strongly set aside the directions against the police officials, holding that the discrepancies in documents (different handwriting, inks) were not sufficient grounds to conclude fabrication and that the Judge had overstepped by directing how an investigation should be conducted.

1. Heading for the Judgment

In the High Court of Delhi at New Delhi

CRL.M.C.2431/2017 & CRL.M.A.9874/2017
CRL.A.1548/2025

RAMESH CHANDER & ORS. ....Petitioners (in CRL.M.C.2431/2017)
STATE (GOVT OF NCT OF DELHI) ....Appellant (in CRL.A.1548/2025)
versus
STATE (NCT OF DELHI) & MEETU SINGH ....Respondents

Coram: Hon'ble Ms. Justice Neena Bansal Krishna

Date of Decision: 09th FEBRUARY, 2026

2. Legal Framework

This judgment operates within the following legal framework:

The Code of Criminal Procedure, 1973 (Cr.P.C.):
Section 378(1): Empowers the State to file an appeal against an order of acquittal passed by a trial court.
Section 482: Saved the inherent powers of the High Court to make such orders as may be necessary to prevent abuse of the process of any court or to secure the ends of justice. The complainants invoked this provision to challenge the acquittal.
Section 313 & 281: Relate to the examination of the accused and recording of statements.
Section 167: Pertains to procedure when investigation cannot be completed in twenty-four hours.
Section 173: Relates to the report of police officer on completion of investigation.
Section 220: Pertains to the framing of charges for distinct offences.
The Wild Life (Protection) Act, 1972:
Section 30: Prohibits dealing in trophies and animal articles without a license.
Section 40 & 41: Deal with the declaration and transfer of captive animals and trophies.
Section 49 & 49B: Prohibit dealings in certain animal products.
Section 50: Empowers officers to enter, search, arrest, and detain. A crucial provision: a police officer not below the rank of Sub-Inspector is empowered to inspect and seize wildlife products in contravention of the Act.
Section 51: Prescribes the penalty for offences under the Act.
Section 55: Deals with the filing of complaints.
The Indian Penal Code, 1860 (IPC):
Section 167: Public servant framing an incorrect document with intent to cause injury.
Section 220: Commitment for trial or confinement by person having authority who knows he is acting contrary to law.
Section 34: Acts done by several persons in furtherance of common intention.

Related Precedents Cited and Relied Upon:

Radhey Shyam vs. State of Haryana, (2001) 10 SCC 206: (Supreme Court) - Cited for the principle that if an FIR number is mentioned on a seizure memo prepared before the FIR was registered, it casts doubt on the prosecution's case.
Prithvi Pal Singh @ Munna vs. State, 2000 (1) JCC (Delhi) 274: (Delhi High Court) - Held that procedural abrasions, such as the FIR number appearing on a memo prepared before the FIR, reflect on the veracity of the prosecution case and rob the efficacy of the evidence.
Bunty @ Guddu vs. State of M.P., AIR 2004 SC 261: (Supreme Court) - Cited by the appellants for the proposition that the prosecution is not required to examine all members of a raiding party and can choose a few to avoid repetitive testimony.

3. Basic Relevant Facts of the Case

The Incident (04.05.2012): Based on secret information, a raiding team from the Crime Branch apprehended the respondent, Meetu Singh, at Karnal Bypass. Three leopard skins were allegedly recovered from his possession. A seizure memo (Ex. CW1/A) was prepared. An FIR (No. 121/2012) under the Wildlife Act was registered.
Trial Court Conviction (22.10.2016): The learned ACMM convicted Meetu Singh under Section 51 of the Wildlife Act, relying on the testimony of the police witnesses and a forensic report confirming the skins were of a leopard (a Schedule I animal).
Sessions Court Acquittal (06.05.2017): In appeal, the learned Special Judge (CBI) acquitted Meetu Singh. The Judge found serious discrepancies:
The documents (Disclosure Statement, Arrest Memo, Personal Search Memo) were in three different handwritings and inks.
The signatures of the I.O., Inspector Satya Prakash, appeared different on different documents, suggesting they might have been forged or obtained later.
The seizure memo (Ex. CW1/A) mentioned the FIR number at the top, even though it was prepared before the FIR was registered, creating doubt about the recovery itself.
It appeared that ASI Ramesh (a rank lower than SI) had actually conducted the investigation, which is not permitted under Section 50 of the Wildlife Act. The involvement of Inspector Satya Prakash seemed to be a manipulation to satisfy the legal requirement.
Directions by Sessions Judge: The Sessions Judge directed that a copy of the judgment be sent to the Joint Commissioner (Vigilance) for disciplinary action against four police officials (Inspector Satya Prakash, ASI Ramesh, Const. Rampal, HC Jagbir) and ordered the registration of a formal FIR against them under Sections 167/220/34 IPC. He also directed that the original documents be sent to CFSL for expert comparison.
Proceedings Before High Court: Two matters came before the High Court:
CRL.M.C.2431/2017: Filed by the complainants/police officials challenging the acquittal of Meetu Singh.
CRL.A.1548/2025: Filed by the State challenging the directions for disciplinary action and registration of FIR against the police officials.

4. Issues in the Judgment

The court addressed the following primary issues:

Validity of Acquittal (Issue in CRL.M.C.): Whether the Sessions Judge was correct in acquitting the accused, Meetu Singh, by giving him the benefit of doubt based on discrepancies in the documents and the manner of recovery.
Validity of Directions Against Police (Issue in State Appeal): Whether the Sessions Judge was justified in directing a disciplinary inquiry and the registration of an FIR against the four police officials, and in giving specific directions on how the investigation against them should be conducted (e.g., sending documents to CFSL).

5. Ratio Decidendi (The Reasoning of the Court)

The High Court's reasoning was bifurcated, addressing each issue separately.

On the Acquittal of Meetu Singh (Dismissing the Complainants' Petition):
Discrepancies in Documents: The court held that while different handwriting and inks on documents prepared at a busy crime scene are not, by themselves, proof of manipulation, they contribute to the overall doubt. The more significant issue was the FIR number on the seizure memo.
Applying Precedent: Relying on Radhey Shyam and Prithvi Pal Singh, the court affirmed that the presence of an FIR number on a memo allegedly prepared before the FIR was registered is a serious procedural anomaly that "creates a doubt about the recovery itself."
Manner of Apprehension: The court noted the ambiguity in the prosecution's case about how the accused reached the spot (a bus ticket was recovered but not produced). This further weakened the narrative.
Conclusion: The cumulative effect of these doubts meant that the Sessions Judge was correct in extending the "benefit of doubt" to the accused. The acquittal was upheld, and the complainants' petition was dismissed.
On the Directions Against Police Officials (Allowing the State's Appeal):
Overstepping Jurisdiction: The High Court held that the Sessions Judge's conclusions about fabrication and forgery were not the only possible inferences. The discrepancies could also be explained by the chaotic nature of on-the-spot investigations. Therefore, the directions for disciplinary action and criminal prosecution were "absolutely unwarranted."
Impermissible Micro-Management: The court strongly criticized the Sessions Judge for giving specific directions on how the investigation against the police should be carried out (e.g., sending documents to CFSL). This is the sole prerogative of the investigating agency. A judge cannot dictate the mode and manner of an investigation.
Expunction of Remarks: The court effectively expunged the strictures and set aside the entire portion of the Sessions Court's order that directed action against the police officials.

6. New Legal Framework Established

This judgment does not establish a new legal principle but serves as an important clarification on the limits of judicial overreach, particularly in the context of acquittals. Its key contributions are:

Distinction Between "Doubts Leading to Acquittal" and "Proof of Fabrication": The judgment clarifies that a judge who acquits an accused by giving them the "benefit of the doubt" based on procedural inconsistencies is not automatically justified in concluding that the police have fabricated evidence. There is a significant gap between "evidence is not reliable enough to convict" and "evidence is a deliberate forgery." The former is a finding for acquittal; the latter requires a higher standard of proof and is not an automatic corollary of the first.
Judicial Restraint in Directing Investigations: The judgment firmly reiterates that while a court can order an investigation into a cognizable offence, it cannot micro-manage the investigation by directing specific steps like which documents to send to which expert. That domain belongs exclusively to the investigating officer. This protects the separation of powers between the judiciary and the executive (police).

7. Examination and Analysis by the Court

The court's analysis was balanced and demonstrated a clear understanding of criminal jurisprudence.

Two-Step Analysis: The court wisely separated the two issues. It first dealt with the accused's acquittal, then separately with the directions against the police.
Nuanced View on Discrepancies: The court showed a practical understanding of police work, noting that different people may prepare documents at a scene. However, it drew a firm line at the FIR-on-seizure-memo discrepancy, which is a well-established legal flaw.
Deference to the Benefit of Doubt: The court correctly applied the principle that if two views are possible on the evidence, and one favors the accused, the appellate court should not interfere with an order of acquittal that takes that view.
Strong Correction of Judicial Overreach: The court's strongest language was reserved for the Sessions Judge's directions. By setting them aside, the High Court reasserted the boundaries of judicial power and protected investigating officers from potentially frivolous consequences arising from a judge's speculative inferences in an acquittal order.

8. Critical Analysis and Final Outcome

Critical Analysis:

This judgment is a model of judicial balance, protecting the rights of the accused while simultaneously guarding against unwarranted judicial overreach against the police.

Strengths: The primary strength is its nuanced and balanced approach. It correctly upholds a valid acquittal based on procedural doubts, which is essential for a fair criminal justice system. Simultaneously, it firmly protects the police officials from the grave consequences of the Sessions Judge's speculative and overreaching directions. The court correctly identified that the Sessions Judge had conflated "doubt" with "proof of fabrication." The criticism of the direction to micro-manage the investigation is legally sound and reinforces the constitutional separation of powers.
Correctness: The decision is legally sound. The acquittal was based on a well-established ground (doubt created by FIR number on seizure memo). The setting aside of the directions against the police is also correct, as a judge cannot act as an investigator or dictate the terms of an investigation.
Potential Impact: This judgment serves as a crucial check on lower courts. It reminds them that while they have the power to acquit and to order investigations, they must not let their suspicions about a case lead them to prejudge and direct action against individuals without a proper evidentiary basis and without respecting the role of the investigating agency. It protects police officers from being targeted merely because their investigation was sloppy enough to lead to an acquittal, absent concrete evidence of malicious intent.

Final Outcome:

The High Court disposed of both matters with the following orders:

CRL.M.C.2431/2017 (by complainants): Dismissed. The acquittal of Meetu Singh was upheld.
CRL.A.1548/2025 (by the State): Allowed in part. The directions issued by the Sessions Judge for disciplinary action and registration of FIR against the four police officials were set aside as unwarranted.