The Delhi High Court has held that while a Magistrate can direct further investigation if dissatisfied with a police report, a trial court cannot seek statistical information that has no bearing on the investigation in the case before it.

Justice Manoj Jain made the observation while dealing with three petitions filed by Station House Officers (SHOs) challenging directions issued by the trial court in three cases registered under the Delhi Excise Act, 2009 following the recovery of illicit liquor. The Bench remarked:

“Manifestly, the information sought for has no bearing with the ongoing investigation…It is not amply clear as to what fruitful outcome would be achieved if such data and statistical information is placed before the learned Trial Court.”

The cases arose from the recovery of illicit liquor. During the investigation, the police attempted to ascertain the source and supplier of the liquor but were unable to trace them, citing a lack of concrete information regarding their identity.

While considering the charge sheets, the trial court observed that the investigating officer had not made sufficient efforts to trace the source of the illicit liquor.

It consequently issued notices to the SHOs, directing them to furnish the total number of charge sheets filed since 1 January 2025 in which Section 33 of the Delhi Excise Act had been invoked, along with the number of cases in which the source of the illicit liquor had been traced and the supplier apprehended or made to join the investigation.

The SHOs challenged the directions before the High Court, contending that the trial court had exceeded its jurisdiction by seeking information unrelated to the investigations in the three cases.

At the outset, the High Court noted that a Magistrate has ample power to direct further investigation where it is not satisfied with the final report submitted by the police. However, it held that the particular directions issued by the trial court had “no real nexus” with the investigation in the three matters.

The Bench observed that although the objective sought to be achieved by the trial court might have been “well-merited and laudable”, it had “gone overboard in its over-anxiety to do justice”. It further held that the procedure adopted and the directions issued by the trial court were not warranted.

Accordingly, the High Court set aside the directions requiring the SHOs to furnish the statistical information, while clarifying that the trial court remained at liberty to direct the investigating agency to conduct further investigation, if necessary.

For Petitioner: Mr. Sanjeev Bhandari, Senior Advocate with Mr. Sushant Bali and Mr. Arjit Sharma, Advocates

For Respondent: Mr. Sunil Kumar Gautam, APP for State with Insp. Vipin Kumar and SI Srikant Yadav, PS Vasant Kunj South

Case Title :  Parveen Kumar Yadav v. State (NCT of Delhi)Case Number :  CRL.M.C. 6258/2026CITATION :  2026 LLBiz HC (DEL) 905
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