CBI transfer requires exceptional grounds; false pleadings may still trigger lawful action where discrepancies are serious.

Transfer of investigation to the CBI is an exceptional remedy, available only where the record shows lack of investigative credibility, need to protect public confidence, or necessity to do complete justice; on the facts, the completed police investigation, filed charge sheets, and recorded statements did not provide a prima facie basis for such interference, so the request failed. Allegations of false pleadings and evidence may justify further action where there are serious discrepancies and the interests of justice require it; the Court left the matter to the State and the CBI to proceed according to law, including offences relating to false charge and false evidence. The writ petition was dismissed with exemplary costs.

---

---

Issues: (i) Whether the investigation of the incidents alleged in the writ petition should be transferred to the CBI; (ii) Whether the Court should initiate action in respect of the allegedly false pleadings and evidence and grant the Union of India's interlocutory prayer for appropriate proceedings.

Issue (i): Whether the investigation of the incidents alleged in the writ petition should be transferred to the CBI.

Analysis: Directions for investigation by the CBI are not to be issued routinely or merely because allegations are made against the local police. Such power is to be exercised sparingly and only in rare and exceptional cases where credibility of investigation is lacking, public confidence requires intervention, or complete justice demands it. On the record, the Court found that the FIRs had already been investigated, charge sheets had been filed, and the materials did not disclose any prima facie basis to attribute the alleged offences to the police or paramilitary forces. The statements recorded before the District Judge also did not support the writ petitioners' narrative.

Conclusion: No case was made out for transfer of investigation to the CBI. The prayer was rejected.

Issue (ii): Whether the Court should initiate action in respect of the allegedly false pleadings and evidence and grant the Union of India's interlocutory prayer for appropriate proceedings.

Analysis: For proceedings relating to false evidence or perjury, the governing provisions require a deliberate falsehood and a finding that it is expedient in the interests of justice to proceed. The Court noted the serious discrepancies in the pleadings and the statements recorded, and held that the matter warranted further action. Without finally determining guilt, the Court considered it appropriate to leave the matter to the State of Chhattisgarh and the CBI for action in accordance with law, including but not limited to offences concerning false charge and false evidence. The bar under Section 195 did not prevent such action on the facts of the case.

Conclusion: The interlocutory prayer for appropriate action was granted to that extent, and the matter was left to the State and the CBI to proceed according to law.

Final Conclusion: The writ petition failed and was dismissed with exemplary costs, while the request for further action on the false-complaint allegations was left open for the competent authorities to pursue in accordance with law.

Ratio Decidendi: A direction to transfer investigation to the CBI requires a prima facie showing of exceptional circumstances and cannot rest on mere allegations; where the record shows completed investigation and no credible basis for interference, the prayer must fail.

---