This compilation indexes twelve rulings — from the Gujarat High Court, Karnataka High Court, Bombay High Court, and the Supreme Court of India — in which Section 156(3) of the Code of Criminal Procedure (CrPC) / Bharatiya Nagarik Suraksha Sanhita (BNSS) featured as a principal or co-cited provision. The cases span July 2018 to March 2026 and arise across a variety of criminal complaint, quashing petition, anticipatory bail, and revision petition contexts. The index is intended for legal researchers, in-house counsel, and litigation support teams who need a structured starting point for tracing judicial treatment of magistrate-directed investigation orders.

Research index only. This page compiles publicly available court orders for research and reference purposes. Nothing on this page constitutes legal advice, and readers must verify each ruling against the full judgment text before relying on it in any proceeding.

The statutory framework in one paragraph

Section 156(3) of the Code of Criminal Procedure, 1973 (and its successor provision in the Bharatiya Nagarik Suraksha Sanhita, 2023) empowers a Judicial Magistrate to order the police to investigate a cognisable offence even before a complaint is formally tried under Section 200 CrPC. The provision is exercisable at the pre-cognisance stage and enables a complainant who has been unable to obtain police registration of an FIR under Section 154 to approach the Magistrate directly. Orders passed under Section 156(3) have been the subject of extensive litigation — at High Courts exercising supervisory jurisdiction under Section 482 CrPC or Articles 226/227 of the Constitution, and before the Supreme Court — concerning the propriety, scope, and quashability of such directions.

The 12 rulings

1. Tahir Ahmed Husen Mohan vs State Of Gujarat

Bench: Gujarat High Court
Date: 23 March 2026
Sections engaged: 15, 156(3), 2(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The application (R/Criminal Misc. Application No. 5489 of 2026) was filed under the Bharatiya Nagarik Suraksha Sanhita, 2023 by the applicant-accused seeking successive anticipatory bail in connection with F.O.R. No. MSKC-2/10/2024-25 dated 14.06.2024, registered with the Mandvi, Surat Forest Department, for offences under the Indian Forest Act and the Wildlife (Protection) Act, 1972. The source preview is procedural in nature and does not disclose the substantive ground on which the order was passed; the matter was heard by the Gujarat High Court on 23 March 2026.

2. Smt. Parvathi vs Directorate Of Enforcement

Bench: Karnataka High Court
Date: 7 March 2025
Sections engaged: 50, 156(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Criminal Petition No. 1132 of 2025), filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, sought to quash the investigation in ECIR bearing F.No.BGZO/25/2024 registered by the Directorate of Enforcement against the petitioner, arising out of the predicate offence in CR.No.11/2024 registered by the Lokayuktha Police; the petition also sought quashing of summons issued under Section 50 of the Prevention of Money Laundering Act vide two summons dated 03.01.2025 and 24.01.2025. The matter was reserved on 20.02.2025 and pronounced on 07.03.2025 by the Karnataka High Court; the source preview does not disclose the operative outcome.

3. Sri Naleen Kumar Kateel vs The State Of Karnataka

Bench: Karnataka High Court
Date: 3 December 2024
Sections engaged: 200, 156(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Criminal Petition No. 10321 of 2024) was filed under Section 482 CrPC seeking to quash the entire proceedings in CR.No.224/2024 registered by Tilaknagar Police Station, Bengaluru, on the file of the learned XLII ACJM, Bengaluru City, for alleged offences arising out of PCR.No.4880/2024 filed by the second respondent, and to set aside the order dated 27.09.2024 in PCR.No.4880/2024. The matter was reserved on 20.11.2024 and pronounced on 03.12.2024; the source preview does not disclose the operative finding.

4. Priti Agarwalla vs The State Of Gnct Of Delhi

Bench: Supreme Court of India
Date: 17 May 2024
Sections engaged: 3(1)(s), 156(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter (Criminal Appeal No. 348 of 2021, citation 2024 INSC 437, marked non-reportable) was heard by the Supreme Court of India in its criminal appellate jurisdiction. The source preview indicates a complex complaint history involving multiple complaints filed before the SHO, P.S. Fatehpur Beri, between April 2018 and thereafter, with some converted into FIRs (FIR No. 135/2018 and FIR No. 134/2018) and quashing petitions pending before the Delhi High Court in related proceedings; the source preview does not disclose the operative holding of the Supreme Court in this appeal.

5. Sahil Zahid Khan vs State Of Maharashtra And Anr

Bench: Bombay High Court
Date: 24 April 2024
Sections engaged: 12(a), 156(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant sought anticipatory bail (Anticipatory Bail Application No. 3519 of 2023, with Interim Application No. 4597 of 2023) before the Bombay High Court in connection with C.R.No.473/2023 registered at Matunga Police Station, Mumbai on 7.11.2023 under various provisions of the IPC and under Section 12(a) of the Maharashtra Prevention of Gambling Act, 1887. The source preview is procedural in nature and does not disclose the substantive ground on which the order was passed or the outcome of the anticipatory bail application.

6. Sri.N. Suryanarayana Reddy vs Smt.N.Poornima

Bench: Karnataka High Court
Date: 6 October 2023
Sections engaged: 156(3), 200
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Criminal Petition No. 8068 of 2023) was filed before the Karnataka High Court and the source preview discloses a dispute involving multiple respondents, the State of Karnataka (through Gandhinagar Police Station, Ballari), and private respondents residing in Ballari and other locations. The source preview is limited to party and counsel identification; the substantive ground and operative outcome are not disclosed in the available preview.

7. Sri. N Bharath Reddy vs Sri. C Sunil Kumar

Bench: Karnataka High Court
Date: 6 October 2023
Sections engaged: 156(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Criminal Petition No. 8076 of 2023) was filed under Section 482 CrPC praying to quash the complaint registered before the Principal Civil Judge and JMFC, Ballari in PCR No.74/2022 and the consequential order dated 28.02.2022 directing investigation under Section 156(3) of the CrPC, for offences alleged under Sections 420, 465, 468, 471, 406 read with Sections 120-B, 114, 182, and 191 of the IPC. The source preview does not disclose the substantive reasoning or operative outcome of the petition.

8. Brigade Enterprises Limited vs State Of Karnataka

Bench: Karnataka High Court
Date: 17 October 2022
Sections engaged: 156(3), 200
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter (Writ Petition No. 14761 of 2021, GM-RES) was filed before the Karnataka High Court by Brigade Enterprises Limited, a company incorporated under the Companies Act, 1956, along with its Chairman and Managing Director and Directors, against the State of Karnataka. The source preview is limited to party identification and does not disclose the substantive ground of challenge or the operative outcome of the writ petition.

9. Smt Aruna Kannur vs State Of Karnataka By

Bench: Karnataka High Court
Date: 12 September 2022
Sections engaged: 120, 156(3), 200, 3(1)(g), 3(1)(x)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petitions (WP No. 13059 of 2019 c/w WP No. 27468 of 2019) were filed under Articles 226 and 227 of the Constitution of India read with Section 482 CrPC, praying to set aside the complaint registered in PCR No. 68/2018 pending before the LXXI Addl. City and Sessions Judge and Special Judge at Bengaluru. The petitioners included the President and an office-bearer of the Kailash Apartment Owners Welfare Association, Mysore Road, Bengaluru; the source preview does not disclose the operative outcome.

10. Sri. Narayana Swamy T vs The State Of Karnataka

Bench: Karnataka High Court
Date: 8 July 2022
Sections engaged: 154(1), 156(3), 164, 200
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter (Writ Petition No. 5316 of 2020, GM-RES) was filed before the Karnataka High Court by eight petitioners, all residing at Puttenahalli Village, J.P.Nagar, 7th Phase, Bengaluru South Taluk, against the State of Karnataka (through the Secretary, Home Department), the Commissioner of Police, Bengaluru City, and the Station House Officer, Koramangala Police Station, among others. The source preview is limited to party and venue details and does not disclose the substantive challenge or operative outcome.

11. T. Sunkappa S/O Late Husenappa vs B. Janardhan S/O Smt. B. Thippanna

Bench: Karnataka High Court
Date: 25 November 2020
Sections engaged: 156(3), 203, 3(1)(x)
Outcome: Outcome not specified in source
Procedural / substantive ground: The criminal revision petition (CRL.RP.No. 2292 of 2011), filed before the Karnataka High Court, Dharwad Bench, under Sections 397 read with 401 CrPC, sought to set aside the judgment and sentence dated 30.08.2011 passed by the Additional Sessions Court, Bellary in PC No.07/2008, and to allow the complaint filed by the petitioner and direct consideration of the case on merits. The revision petition was preferred by the complainant aggrieved by an adverse order at the trial court; the source preview does not disclose the operative outcome of the revision.

12. Marwadi Shares And Finance Limited vs State Of Gujarat

Bench: Gujarat High Court
Date: 13 July 2018
Sections engaged: 156(3), 29
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (R/Criminal Misc. Application No. 2861 of 2008) was filed under Section 482 CrPC before the Gujarat High Court at Ahmedabad for quashing of Criminal Case No. 16 of 2008 pending in the Court of the Chief Judicial Magistrate, Jamnagar; the criminal case was filed for an offence under Sections 40 and related provisions (as per the source preview). The source preview does not disclose the full list of offences alleged or the operative outcome of the quashing petition.

Patterns across these 12 rulings

Section 482 CrPC / supervisory jurisdiction as the primary challenge route. Across multiple cases in this set — including Cases 3, 6, 7, 8, 9, and 12 — the procedural vehicle used to challenge proceedings connected with Section 156(3) is Section 482 CrPC or Articles 226/227 of the Constitution, reflecting the established pattern of aggrieved accused persons approaching the High Court to quash magistrate-directed investigation orders or the underlying complaints.
Karnataka High Court as a recurrent forum. Eight of the twelve cases (Cases 2, 3, 6, 7, 8, 9, 10, and 11) were decided by the Karnataka High Court, with several from the same court division, suggesting active litigation of Section 156(3)-related matters in Karnataka across the 2019–2025 period.
Co-citation of Section 200 CrPC. Section 156(3) and Section 200 CrPC are frequently co-cited across Cases 3, 6, 8, 9, and 10, reflecting the practical intersection between the magistrate's power to direct police investigation (pre-cognisance) and the cognisance route through examination of the complainant on oath.
Diverse subject-matter underlying the Section 156(3) invocation. The provision appears across widely varied factual contexts in this set — including forest and wildlife offences (Case 1), PMLA summons (Case 2), political complaint matters (Cases 3 and 4), gambling offences (Case 5), civil disputes converted into criminal complaints (Cases 6 and 7), real-estate corporate disputes (Case 8), apartment association disputes (Case 9), and securities-related matters (Case 12) — illustrating that the procedural provision is invoked across substantive law regimes.
Outcome data unavailable in source for all twelve cases. All twelve entries in this compilation carry the outcome designation "Outcome not specified in source," meaning that the operative directions of the courts cannot be stated from the available previews. Researchers must obtain the full judgment text to determine the actual holding in each matter.

How to use this compilation

This index is a structured starting point for locating cases that engage Section 156(3) CrPC across Indian High Courts and the Supreme Court. Each entry provides the authoritative case identity — bench, date, co-cited sections, and available outcome designation — drawn from the TaxNoticeAI structured legal corpus. Before relying on any case for a legal proposition, researchers should obtain and read the full judgment text from the original court portal (indiankanoon.org, the Karnataka High Court portal, the Gujarat High Court portal, the Bombay High Court portal, or the Supreme Court of India's website) and verify that the preview-level description in this index is consistent with the complete order.

Researchers should also check whether any ruling listed here has been subsequently stayed, reversed, or modified in appeal or revision. Several cases in this set involve ongoing or multi-stage proceedings (for example, Cases 3, 4, and 12 indicate earlier or parallel proceedings), and the position recorded here reflects only the order identified by the corpus at the indexed date. Checking for subsequent developments — whether through an appellate order, a Supreme Court special leave petition, or a remand — is essential before treating any ruling as final.

Finally, while this compilation is indexed under the Section 156(3) CrPC topic for search and research purposes, users should note that the co-cited provisions vary across cases (ranging from PMLA Section 50, to IPC provisions, to special Acts) and the substantive legal issues in each case may be governed primarily by a provision other than Section 156(3). Readers are advised to verify parallel CBDT circulars, Ministry of Home Affairs guidelines, or other applicable regulatory instructions where the underlying subject-matter of the dispute intersects with tax, financial regulation, or related fields.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 156(3) CrPC: 12 High Court & Supreme Court Rulings on Magistrate-Directed Investigation Orders