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IN THE HIGH COURT OF JUDICATURE AT MADRAS
L.VICTORIA GOWRI
Valarmathi – Appellant
Versus
State of Tamil Nadu – Respondent
ORDER :
1. Seeking to transfer the investigation in Cr.No.282 of 2022 from the file of third Respondent to file of the fourth Respondent, this criminal original petition is filed.
2. The learned counsel appearing for the petitioner submitted that the petitioner had lodged a complaint regarding the loss of 10 sovereigns of gold jewellery. It was further submitted that, as there has been no substantial progress in the investigation, the present petition has been filed.
3. When the matter came up for hearing, the learned Government Advocate (crl.side), on instructions, submitted that investigation in Crime No.282 of 2022 has been completed and the same was closed as 'undetected'. RCS notice has also been sent to the petitioner on 05.02.2025.
4. Heard the learned counsel on either side.
5. In a similar nature of this case, this Court passed an order in Crl.OP(MD)Nos.10290 of 2025 dated 25.11.2025 and the relevant portion of the order reads as follows:-
“36. The Hon'ble Supreme Court in Rattiram and Others v. State of Madhya Pradesh, AIR 2012 SC 1485, emphasised the concept of “victimology” and recognised that criminal jurisprudence must evolve to protect victims as rights-bearing participan
The State's failure to conduct effective investigations violates victims' rights under Article 21, necessitating compensation and accountability for systemic failures.
The state has a non-delegable duty to conduct effective investigations in criminal cases, failing which victims are entitled to compensation under Article 21.
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