A coordinated approach between law enforcement and judicial processes is essential for effective crime investigation and timely court proceedings.

Headnote:(A) Indian Penal Code, 1860 - Sections 406 and 420 - Complaint lodged alleging cheating through spurious gold - Petition for directing investigation completion by Police - Court observed miscommunication by the Government Advocate - Recommendations for improving Police communication and efficiency. (Paras 1, 9, 18, 26)

(B) Criminal investigation - Compliance and cooperation from complainants essential for effective investigation - Importance of accurate representations in court proceedings. (Paras 2, 10, 11)

Facts of the case:
The Finance Company alleged cheating involving spurious gold worth Rs.16,80,900/- leading to the registration of a case under IPC Sections 406 and 420. The petitioner claimed non-cooperation from the Police hindered the investigation.

Findings of Court:
The Court observed that false representation was made regarding document requests from the complainant which stalled the process, and emphasized the need for accurate police instructions to avoid systemic delays.

Issues: Whether the police's claim of non-cooperation by the complainant affected the investigation timeline and the implications of inaccurate government representations to the Court.

Ratio Decidendi: The Court highlighted the importance of genuine communication from law enforcement in judicial processes, emphasizing that procedural inefficiencies must be rectified to improve case handling efficiency.

Result: The Director General of Police and Secretary to Government, Home Department, were instructed to implement recommended improvements.

ORDER

The petitioner / Finance Company has lodged a complaint before the Karur Town Police Station alleging that it had been cheated by an accused who pledged spurious gold to the extent of 418.4 grams, resulting in a loss of Rs.16,80,900/-. Based on the said complaint, a case in Crime No.733 of 2023 was registered on 23.11.2023 for the offences punishable under Sections 406 and 420 IPC . The present petition has been filed seeking a direction to the respondent Police to conclude the investigation and file the final report within a stipulated time.

2.When the application came up for hearing on 25.07.2025, a representation was made on behalf of the respondent Police that two witnesses had been examined and that certain documents were sought from the defacto complainant. It was further submitted that the defacto complainant had not co-operated with the investigation and failed to produce the requisite documents, thereby stalling the investigation.

3.The petitioner, on the contrary, alleged that the Police had failed to act upon its complaint. In response, the learned Government Advocate appearing for the Police reiterated that the petitioner had not co-operated. When a specific query was posed by this Court regarding the documents required from the defacto complainant, the Officer who had come to assist the learned Government Advocate was unable to respond.

4.Therefore, this Court, by order dated 25.07.2025, directed the respondent Police to produce copies of any summons, if issued, calling upon the petitioner to produce documents necessary for the investigation, and adjourned the matter to 05.08.2025.

5.A report has now been filed by the Deputy Superintendent of Police, Karur Town Sub-Division, stating that the investigation in Crime No.733 of 2023 was in fact completed, and that the final report had been filed on 11.01.2024. It is further stated that the final report has been submitted for e-filing under LTN-20220001469C202500453 on 27.07.2025.

6.Curiously, this report is silent as to the documents that were earlier claimed to be pending from the defacto complainant. Yet, on 25.07.2025, a categorical representation was made before this Court that the investigation was incomplete due to non-cooperation by the defacto complainant and non-production of certain documents.

7.A communication dated 31.07.2025, addressed by the Inspector of Police, Karur Town Police Station, to the Superintendent of Police, Karur, has also been placed on record. It reveals that two Special Sub-Inspectors of Police, namely Tr. Palanichamy [1092] and Tr. Padmaseelan [900], were deputed to appear before this Court and they had provided instructions in a casual and uninformed manner without properly verifying the CD file. Consequently, the Inspector of Police has recommended initiation of disciplinary proceedings against the said officers for having furnished vague and careless information to the Court.

8.Though it is now claimed that the investigation was completed and the final report filed as early as 11.01.2024, it was submitted for e-filing only on 27.07.2025, ie., after the order passed by this Court on 25.07.2025.

9.From the records, it is apparent that there were, in fact, no outstanding documents required from the defacto complainant, contrary to the representation made on 25.07.2025. The learned Government Advocate, acting upon the instructions provided to him by the officials, submitted that the delay in the investigation was due to the petitioner’s non- cooperation. Therefore, it is clear that a false representation was made before this Court on that day.

10.Courts rely on the submissions made by both sides in order to render just decisions. The State’s representations, particularly those advanced by the learned Government Advocate, carry weight and are presumed to be based on verified instructions. In the present case, it has now come to light that the instructions given were inaccurate and misleading.

11.Although disciplinary action is stated to have

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