BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT Dated : 13.02.2026 CORAM THE HONOURABLE MRS. JUSTICE L. VICTORIA GOWRI CRL OP(MD). No.3060 of 2026 G.Keerthika ... Petitioner/Defacto Complainant Vs

1. The State of Tamilnadu Rep by, The Inspector of Police, G-1, Pattukottai Town Police Station, Pattukottai, Thanjavur.

(In Crime No.484 of 2025) ... Respondent/Complainant PRAYER :-

To direct the respondent police to conduct investigation and to file a final report in Crime No.484 of 2025 on the file of the respondent police under Section 406, 420 & 506(i) of IPC, 1860, as against the accused persons.

For Petitioner : Mr.D.Mani Advocate.

For Respondent : Mr.B.Thanga Aravindh Government Advocate (Crl.Side)

ORDER

Preface:

The advent of the Bharatiya Nyaya Sanhita, 2023, the Bharatiya Nagarik Suraksha Sanhita, 2023, and the Bharatiya Sakshya Adhiniyam, 2023 marks a constitutional transformation in India’s criminal jurisprudence. For the first time since Independence, the criminal process has been consciously re-engineered to be victim-centric, citizen- responsive and justice-oriented, in contrast to the colonial enactments which were historically designed to subserve the interests of an imperial administration and to control its subjects.

2.The new Codes emphasise timeliness, transparency, accountability, and proportionality, recognising delay as a denial of justice. In particular, the BNSS, 2023, by codifying strict timelines for investigation in Section 193, ensures that the investigating agency cannot indefinitely keep the sword of uncertainty hanging over the head of an accused or allow victims to languish without closure. It is in this mandate of constitutional justice that the present petition deserves to be examined.

3. This Criminal Original Petition has been filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking a direction to the respondent to file a final report with respect to the Crime No.484 of

2025.

Submissions:

4. The learned counsel for the petitioner submits that though the FIR was registered on 27.07.2025, no final report has been filed till date. Such delay is contrary to the statutory mandate under Section 193 BNSS, which prescribes time-bound investigation. It is therefore prayed that necessary directions be issued.

5. The learned Government Advocate (Crl. side) submits that the investigation is in progress and the investigating officer shall abide by any timeline fixed by this Court.

6. Heard the learned counsels on either side and carefully perused the materials available on record.

Analysis:

7. The BNSS has introduced a strict regime of time-bound investigation, which reads as follows:

(i) Section 193(1) BNSS mandates that every investigation under this Sanhita shall be completed without unnecessary delay.

(ii)Section 193(2) BNSS mandates that in relation to offences punishable with imprisonment of seven years or more, the investigation shall ordinarily be completed within ninety days; and in all other offences, within sixty days.

(iii) Section 193(3) BNSS, mandates that if the investigation is not completed within the period prescribed, the investigating officer shall record the reasons in writing and intimate the Magistrate of such delay.

8. The statute therefore creates (i) a positive duty to complete investigation promptly; (ii) outer time limits; and (iii) a compulsory accountability mechanism for delay. These provisions are mandatory in nature and bind the investigating agency.

9.The petitioner/defacto complainant lodged a complaint alleging that the accused persons cheated the petitioner to the tune of Rs.20 lakhs and a vehicle and a mobile phone, following which, first information report in Crime No.484 of 2025 for the offences under Sections 406, 420 & 506(i) of IPC. However, so far, final report has not been filed. Hence, the above petition.

10.This Court notes that the FIR in the present case was registered on 27.07.2025 and the investigation has not culminated in a final report even after the la