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2026 Supreme(Online)(Mad) 12004

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Sunder Mohan, J
L.RAMESH – Appellant
Versus
The Commissioner of Police – Respondent
Crl.R.C.No.248 of 2026



Advocates:
For the Appellants/Petitioners: S. Gnanam
For the Respondents: R. Vinothraja

A negative final report is sustainable and the Magistrate's order accepting it is valid if a prior investigation on the same allegations has already concluded that the claims were false.

Headnote:The petitioner filed a Criminal Revision Case under Section 438 r/w 442 of Bharatiya Nagarik Suraksha Sanhita, 2023, challenging an order dated 07.10.2025 passed by the Metropolitan Magistrate for Exclusive Trial of CCB Cases at Egmore. The petitioner alleged that his signature was forged to obtain a life certificate and execute sale deeds in favor of third parties. The court found that the allegations were previously investigated in a similar complaint filed by the petitioner's mother, which was closed as "further action dropped." The primary issue was whether the order accepting the negative final report filed by the police without registering an F.I.R. was sustainable. The court reasoned that since the allegations regarding the forgery of the signature in the life certificate were found to be incorrect in a prior investigation on the same facts, there was no infirmity in the impugned order. With the above observations, this Criminal Revision Case is dismissed.

Table of Content
1. petitioner challenges the acceptance of a negative final report regarding alleged forgery of signatures. (Para 1 , 2)
2. contention regarding the necessity of an fir versus the existence of a previously closed investigation on identical facts. (Para 3 , 4)
3. acceptance of a negative report is valid when prior investigations prove the allegations to be incorrect. (Para 5 , 6)

Prayer:

Criminal Revision Case filed under Section 438 r/w 442 of Bharatiya Nagarik Suraksha Sanhita, 2023, to set aside the order dated 07.10.2025 in Crl.M.P.No.3529 of 2025 passed by the Metropolitan Magistrate for Exclusive Trial of CCB Cases at Egmore.

ORDER

The petitioner challenges the order of the learned Magistrate accepting the negative final report filed by the respondent herein on the complaint given by the petitioner.

2. It is the case of the petitioner that his signature was forged and a life certificate was obtained, and certain sale deeds were executed in favour of third parties and he lodged a complaint to the Police. Since the Police did not register the complaint, the petitioner approached the learned Magistrate, who passed an order directing the respondent to conduct an enquiry and file a report. As there was a delay in filing the report, the petitioner approached this Court in Crl.O.P.No.28950 of 2025 for a direction to the respondent to comply with the direction of the learned Magistrate. This Court after recording the fact that a report had been filed by the respondent had closed the Criminal Original Petition with liberty to challenge the final report in the manner known to law.

3. The learned counsel for the petitioner would submit that the report of the respondent filed without registering an F.I.R cannot be sustained and consequently, the order accepting the report has to be set aside.

4. The learned Government Advocate (Crl. Side) for the respondents, per contra, would submit that on the very same allegations, the mother of the petitioner had lodged a complaint, which was registered in Crime No.138 of 2022 on the file of the CCB/2nd respondent herein and the same was closed as “further action dropped”. Since the allegations were found to be false, the respondent filed the report, which cannot be faulted.

5. Admittedly, the same complaint given by the petitioner’s mother was closed after registering the F.I.R in Crime No.138 of 2022. The respondent's report states that the allegation that the petitioner’s signature was forged in the life certificate is not correct. Therefore, this Court finds no infirmity in the impugned order. In view of the same, it is open to the petitioner to work out his remedy in the manner known to law.

6. With the above observations, this Criminal Revision Case is dismissed.

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