Substantial justice prevails over procedural irregularities; FIR closure was improperly enforced despite late filing.

COMMON ORDER

These Criminal Revision Cases have been filed challenging the common order passed by the learned Metropolitan Magistrate for Exclusive Trial of CCB Cases (Relating to Cheating Cases in Chennai) and CBCID Metro Cases, Egmore, Chennai, in Crl.M.P.Nos.56516, 56517, 56522 and 56521 of 2024 dated 28.07.2025, whereby the learned Magistrate closed the FIRs on the ground that the final reports were not filed within the time stipulated earlier.

2. Since the issues involved in all these revisions are identical, they are disposed of by this common order.

3. The facts leading to the filing of the above revisions are as follows:

a) Four FIRs were registered against the respondents for the offences under Sections 406, 419, 420 and 120(B) IPC in Crime No.14 of 2023; under Sections 406, 420 and 506(1) IPC in Crime No.17 of 2023; under Sections 406, 420 and 506(1) IPC in Crime No.16 of 2023; and under Sections 409, 420, 506(1) and 120(B) IPC in Crime No.15 of 2023.

b) On a petition filed by one of the de facto complainants, this Court, in W.P.No.23702 of 2023, by order dated 15.09.2023, had transferred the investigation to CBCID and directed the Additional DGP to form a Special Team for investigating all the four cases and to conduct and complete the investigation as expeditiously as possible.

c) Thereafter, the respondents herein filed Crl.M.P.Nos.39936, 39938, 39939 and 40184 of 2024 under Section 173 Cr.P.C., seeking a direction to file the final reports in Cr.Nos.14 to 17 of 2023 expeditiously in terms of the order passed by this Court. The learned Magistrate, by order dated 18.07.2024, directed the respondents to file the final reports within a period of two months. Challenging the said orders, the prosecution filed Crl.M.P.No.1844 of 2024 and Crl.R.C.SR.No.65780 of 2024; Crl.M.P.No.18279 of 2024 and Crl.R.C.SR.No.65779 of 2024; Crl.M.P.No.18443 of 2024 and Crl.R.C.SR.No.65778 of 2024; and Crl.M.P.No.18636 of 2024 and Crl.R.C.SR.No.65783 of 2024. This Court, by orders dated 24.03.2025, 13.02.2025 and 14.02.2025 in the petitions filed to condone the delay, had observed that if the respondents did not file the final reports within the time fixed by the learned Magistrate, the entire proceedings in Crime Nos.14 to 17 of

2023 shall be quashed.

d) Thereafter, from time to time, the petitioners sought extension of time, which was allowed by the learned Magistrate, and the final extension was granted till 28.07.2025.

e) Since the respondents did not file the final reports on 28.07.2025, the learned Magistrate passed the impugned orders closing the FIRs.

4. The learned Government Advocate (Crl. Side) for the petitioners would submit that the charge sheets were filed through e-filing on 28.07.2025 and therefore the impugned orders passed by the learned Magistrate closing the FIRs cannot be sustained and the State must be permitted to prove its case on merits.

5. The learned Senior Counsel for the respondents, however, would submit that the cases have been pending investigation from the year 2023; that the respondents had taken several extensions of time to file the final reports and had not complied with the directions issued either by this Court or by the learned Magistrate; that no proof has been filed to show that the final reports were filed on 28.07.2025 through e-filing; that the learned Magistrate himself had recorded that the charge sheets had not been filed till 5.45 p.m.; and that there is no infirmity in the said orders, and prayed for dismissal of the revisions.

6. It is no doubt true that this Court, while considering the petitions to condone delay filed by the State against the ea