Locus standi in closure report proceedings denied to an investigating agency lacking complainant or victim status.

In proceedings on a police closure report, only the informant or complainant, an injured person, a recognised victim, or another person otherwise entitled in law may be heard. An investigating agency that is neither the complainant nor the victim cannot intervene or file a protest petition without statutory authority or supervisory jurisdiction over the other agency. The Bombay HC therefore treated the Enforcement Directorate as lacking locus standi to oppose the closure report before the Magistrate, and its protest petition was not maintainable. Authorities cited for intervention rights were found distinguishable or inapplicable.

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Issues: Whether the Enforcement Directorate had locus standi to intervene and file a protest petition in the closure report filed by the State before the Magistrate.

Analysis: The Court held that, in proceedings on a closure report, the recognized categories entitled to notice or hearing are the informant or complainant, an injured person, and in appropriate cases the relative or heir of the deceased. A person claiming to intervene must fit within the statutory or judicially recognized category of a victim or otherwise be legally entitled to be heard. The Enforcement Directorate, though an independent investigating agency under other fiscal and economic statutes, was not the complainant, not the injured person, and not a victim within the meaning of the Code. The Court further held that one investigating agency has no supervisory jurisdiction over another, and a Magistrate cannot entertain intervention by a third party outside the categories recognized in law. The authorities relied upon by the petitioner were held to be distinguishable or inapplicable.

Conclusion: The Enforcement Directorate had no locus standi to intervene in the closure report proceedings and its protest petition was not maintainable.

Ratio Decidendi: In proceedings on a police closure report, only the complainant or informant, a statutorily recognized victim, or another person otherwise entitled in law may be heard; an investigating agency that is neither the complainant nor the victim cannot intervene in the absence of statutory authority or supervisory jurisdiction.

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