Locus standi and territorial jurisdiction objections do not automatically bar FIR quashing or police investigation.
A person not named as an accused in the impugned FIR ordinarily lacks locus standi to seek quashing of that FIR or the connected investigation. The Court also held that a territorial jurisdiction objection does not, by itself, bar police investigation of a cognizable offence: under the CrPC, police may register and investigate, and if needed transfer the matter to the competent territorial police. Where judicial permission has been obtained to add the allegation and the investigation concerns conspiracy and related conduct, the challenge to investigation on jurisdictional grounds will not succeed.
Issues: (i) Whether the petitioner, who was not named as an accused in the FIR or the requisition for investigation, had locus standi to seek quashing of the FIR and investigation; (ii) Whether the Karnataka police lacked authority to investigate the alleged offence of extortion and the connected predicate offence on the ground of territorial jurisdiction.
Issue (i): Whether the petitioner, who was not named as an accused in the FIR or the requisition for investigation, had locus standi to seek quashing of the FIR and investigation.
Analysis: The petitioner was not shown as an accused in the crime registered by the Kadugodi police, and his name did not appear in the first information or in the request made for investigation under the added offence. The challenge was directed against a criminal proceeding that was not initiated against him, while the alleged grievance, if any, arose from later action in the connected money-laundering proceedings. The Court treated the absence of the petitioner's name in the FIR and the absence of any direct proceeding against him as decisive for maintainability.
Conclusion: The petitioner had no locus standi to maintain the challenge to the FIR and investigation.
Issue (ii): Whether the Karnataka police lacked authority to investigate the alleged offence of extortion and the connected predicate offence on the ground of territorial jurisdiction.
Analysis: Sections 156 and 181(3) of the Code of Criminal Procedure, 1973 were relied upon to examine the scope of police investigation and the place of trial for extortion. The Court held that an FIR may be registered and investigation may commence even where the offence appears to have links with another place, and that the police may investigate and, if necessary, transfer the matter to the police having territorial jurisdiction. The Court also noted that the police had obtained judicial permission to add the extortion allegation and that the allegation of conspiracy and related conduct required investigation. Since the petitioner was not the accused in the FIR, he could not object to that investigation on jurisdictional grounds.
Conclusion: The Karnataka police were not precluded from investigating the matter at the stage under challenge, and the jurisdictional objection did not warrant quashing.
Final Conclusion: The writ petition failed because the petitioner was not an accused in the impugned crime and the investigation could not be interdicted on the pleaded jurisdictional grounds; the criminal proceeding was therefore allowed to continue.
Ratio Decidendi: A person not named as an accused in the impugned FIR, and against whom no proceeding is initiated in that crime, cannot ordinarily invoke writ jurisdiction to quash the FIR, and territorial objections to investigation do not by themselves justify quashing where the police are empowered to investigate cognizable offences and transfer the matter if required.
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