Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(Mad) 47236

IN THE HIGH COURT OF JUDICATURE AT MADRAS
P. Dhanabal, J
K. Boomadevi – Appellant
Versus
Commissioner of Police, Madurai – Respondent
Criminal Original Petition in Crime No. 484 of 2022

Advocates:
For the Appellants/Petitioners: K.P. Sankarakumarakuruparan
For the Respondents: G. Ganeshkumar

A petition for the transfer of a police investigation under Section 482 of the Cr.P.C. becomes infructuous upon the filing of a closure report, and the aggrieved party must instead challenge such closure report if they wish to contest the investigation's outcome.

Headnote:The petitioner filed a petition under Section 482 of the Code of Criminal Procedure, 1973, seeking the transfer of an investigation from a local police station to a specialized crime division. The primary contention was the perceived lack of progress or inadequate investigation by the local authorities into the registered crime. The core issue addressed was whether the court should exercise its inherent power under Section 482 of the Code of Criminal Procedure, 1973, to compel a transfer of investigation. The Court observed that since the investigation had already concluded with a closure report referred to as 'Action dropped' and the notice had been served upon the complainant, the underlying request for transfer had become infructuous. Consequently, the court disposed of the petition, granting the petitioner the liberty to challenge the final closure report through appropriate legal proceedings.

Table of Content
1. the court maintains that upon the filing of a closure report, the remedy is to challenge said report rather than seek transfer of the defunct investigation. (Para 1 , 2 , 3 , 4 , 5)

O RDER

This criminal original petition has been filed to transfer the investigation in Crime No.484/2022 on the file of the 3^rd respondent to the 2^nd respondent.

2.When the matter is taken up for hearing today, both counsel are present. The learned Government Advocate (Crl. Side) would submit that the case has been closed as 'Action dropped' and RCS Notice was also served upon the defacto complainant.

3.The learned counsel for the petitioner submits that so far they have not received any RCS Notice.

4.The learned Government Advocate (Crl. Side) submits that the copy of the closure report has been served to the learned counsel for the petitioner today also.

5.In view of the submissions made by the learned Government Advocate (Crl. Side), this criminal original petition stands disposed of preserving the liberty of the petitioner to challenge the closure report in the manner known to law, if so aggrieved.

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2026 Supreme(Online)(Mad) 47236

IN THE HIGH COURT OF JUDICATURE AT MADRASP. Dhanabal, JK. Boomadevi – AppellantVersusCommissioner of Police, Madurai – RespondentCriminal Original Petition in Crime No. 484 of 2022

A petition for the transfer of a police investigation under Section 482 of the Cr.P.C. becomes infructuous upon the filing of a closure report, and the aggrieved party must instead challenge such closure report if they wish to contest the investigation's outcome.

IN THE HIGH COURT OF JUDICATURE AT MADRAS
P. Dhanabal, J
K. Boomadevi – Appellant
Versus
Commissioner of Police, Madurai – Respondent
Criminal Original Petition in Crime No. 484 of 2022