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Vinubhai Haribhai Malaviya v. State of Gujarat

Vinubhai Haribhai Malaviya v. State of Gujarat (Supreme Court of India, 2019-10-16) (2019) 17 SCC 1 is a ruling on the Right to Information Act, 2005 — Section Magistrate supervision. Magistrate has continuing supervisory role over investigation. The Magistrate has a continuing supervisory role over police investigation under §156(3) and §173(8) CrPC.

Holding

Magistrate has continuing supervisory role over investigation.

Ratio

The Magistrate has a continuing supervisory role over police investigation under §156(3) and §173(8) CrPC. Further investigation can be ordered even after submission of police report. Useful complement to RTI for FIR-not-registered cases.

Section(s) applied

Practitioner takeaway

Magistrate can order further investigation; complements §156(3) jurisdiction.

Citation

Last reviewed: 23 April 2026.