Mohan Karthik & Ors. v. State of Tamil Nadu & Anr., 2026

The complainant initially filed an application under Section 156(3) CrPC in 2022, which was dismissed by the Magistrate.

The complainant then approached the Madras High Court, which directed a preliminary police inquiry.

After inquiry, the police submitted a closure report in December 2022.

The complainant challenged the closure report, but the High Court dismissed the challenge and granted liberty to file a private complaint under Section 200 CrPC.

Instead of filing a private complaint, the complainant again filed a fresh application under Section 156(3) CrPC in 2024.

The Magistrate accepted this second application and directed registration of FIR.

The accused challenged the FIR, but the High Court upheld it, leading to the appeal before the Supreme Court.

The Supreme Court held that Sections 156(3) and 200 CrPC operate in distinct legal spheres and cannot be treated as interchangeable remedies.

It observed that once the High Court granted liberty to proceed under Section 200 CrPC, the complainant could not again invoke Section 156(3) CrPC.

The Court held that entertaining a second Section 156(3) application amounted to an attempt to indirectly review the High Court’s earlier order.

It found that the Magistrate acted beyond jurisdiction by allowing the second application despite clear judicial directions limiting the remedy.

The Court clarified that the proper course after rejection and closure report was to proceed strictly under Section 200 CrPC.

Accordingly, the Supreme Court set aside the High Court and Magistrate’s orders directing FIR registration.

The Court directed that the Section 156(3) application be treated as a private complaint under Section 200 CrPC and be proceeded with in accordance with law.

The judgment clearly reinforces the procedural distinction between pre-cognizance investigation (Section 156(3)) and post-cognizance complaint mechanism (Section 200).

It prevents abuse of process by repeated invocation of Section 156(3) CrPC after rejection.

The Court emphasized judicial discipline and hierarchy, holding that subordinate courts cannot act contrary to High Court directions.

It strengthens the principle that procedural remedies under CrPC are structured and cannot be selectively re-used to bypass earlier orders.

The judgment also ensures that litigants cannot engage in forum shopping between Sections 156(3) and 200 CrPC.

It protects the integrity of the criminal process by maintaining clear procedural boundaries between investigation and complaint stages.

The Supreme Court held that procedural remedies under Sections 156(3) and 200 CrPC are distinct and cannot be misused interchangeably.

It reaffirmed that once a High Court directs a specific remedy, subordinate courts must strictly comply with it.

The judgment ensures procedural certainty, prevents abuse of criminal process, and maintains judicial hierarchy.