Territorial jurisdiction cannot override a valid section 156(3) investigation order where part of the cause of action lies within jurisdiction.

A Magistrate acting under section 156(3) of the Code of Criminal Procedure can direct investigation and ensure its fairness, and the police cannot defeat that direction by unilaterally raising territorial jurisdiction objections. Where the complaint showed that the complainant was resident in Delhi and part of the cause of action arose there, the Delhi Magistrate had territorial jurisdiction to direct investigation. A police transfer of the investigation to Greater Noida was treated as an impermissible review of the Magistrate's order and was quashed as bad in law.

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Issues: Whether the police could transfer investigation outside Delhi after an order under section 156(3) of the Code of Criminal Procedure, 1973, and whether the Delhi Magistrate had territorial jurisdiction to direct investigation on the complaint.

Analysis: A Magistrate acting under section 156(3) has power to direct investigation and ensure that it is carried out fairly. Once such a direction is issued, the police cannot unsettle it by raising territorial jurisdiction objections on its own. The complaint disclosed that the complainant was resident in Delhi and that part of the cause of action arose there, so the Delhi Magistrate could take cognizance and direct investigation. The transfer of investigation by the police to Greater Noida amounted to an impermissible review of the Magistrate's order and could not be sustained.

Conclusion: The transfer of investigation from Delhi to Noida was held to be bad in law and was quashed.

Ratio Decidendi: When a Magistrate validly orders investigation under section 156(3), the police cannot defeat that order by transferring the investigation on the ground of territorial jurisdiction if part of the cause of action lies within the Magistrate's jurisdiction.

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