Dhruv Bhatia v. State Of Karnataka & ORS.

$~73 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(CRL) 908/2026 & CRL.M.A. 8605/2026 DHRUV BHATIA .....Petitioner Through:

Mr. Shubham Dayma and Ms. Charu Sangwan, Advocates.

versus STATE OF KARNATAKA & ORS.

.....Respondents Through:

Mr. Amol Sinha, ASC for the State.

CORAM:

HON'BLE MR. JUSTICE ANUP JAIRAM BHAMBHANI

O R D E R

% 25.03.2026 By way of the present petition filed under Article 226(2) of the Constitution of India read with section 528 of the Bharatiya Nagarik Suraksha Sanhita 2023, the petitioner seeks quashing of case FIR No.472/2025 dated 15.12.2025 registered under sections 3(5)/314/316(2)/318(3) of the Bharatiya Nyaya Sanhita 2023, at P.S.: HSR Layout, Madivala Sub-Division, Bengaluru City. 2.

Mr. Shubham Dayma, learned counsel appearing for the petitioner submits, that though the subject FIR has come to be registered in Bengaluru, Karnataka, this court would have jurisdiction in relation to the prayer made in the present matter since the accused company - M/s Reinvent Agro Chain Pvt. Ltd., of which company, the petitioner is a director, has its registered office in New Delhi. 3.

Mr. Dayma argues, that the mere fact that the complainant/respondent No.2 has its registered office in Bengaluru, Karnataka does not imply W.P.(CRL) 908/2026 Page 1 of 3 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

that the subject FIR could have been registered in Bengaluru. In this regard, learned counsel has placed reliance on the decision of the Supreme Court in Navinchandra N. Majithia vs. State of Maharashtra1.

4.

However, it is noticed, that vidé order dated 10.02.2026 made in BAIL APPL. No.606/2026, this Bench had granted transit anticipatory bail to the petitioner for a period of 04 weeks, for the limited purpose of affording to the petitioner the liberty and time to approach the court of competent territorial jurisdiction in the State of Karnataka. 5.

After a brief hearing in the matter, this court is of the view that since the complainant has its registered office in Karnataka, and the subject FIR has come to be registered in Bengaluru, Karnataka, this court would not be the competent court of territorial jurisdiction to entertain or decide the present petition, especially in light of the decision of the Supreme Court in Satvinder Kaur vs. State (Govt. of NCT of Delhi)2. The relevant extract of Satvinder Kaur reads as follows: "8. In our view, the submission made by the learned counsel for the appellant requires to be accepted. The limited question is whether the High Court was justified in quashing the FIR on the ground that Delhi Police Station did not have territorial jurisdiction to investigate the offence.

From the discussion made by the learned Judge, it appears that learned Judge has considered the provisions applicable for criminal trial. The High Court arrived at the conclusion by appreciating the allegations made by the parties that the SHO, Police Station Paschim Vihar, New Delhi was not having territorial jurisdiction to entertain and investigate the FIR lodged by the appellant because the alleged dowry items were entrusted to the 1 (2000) 7 SCC 640 2 (1999) 8 SCC 728 W.P.(CRL) 908/2026 Page 2 of 3 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

respondent at Patiala and that the alleged cause of action for the offence punishable under Section 498-A IPC arose at Patiala. In our view, the findings given by the High Court are, on the face of it, illegal and erroneous because:

(1) The SHO has statutory authority under Section 156 of the Criminal Procedure Code to investigate any cognizable case for which an FIR is lodged.

(2) At the stage of investigation, there is no question of interference under Section 482 of the Criminal Procedure Code on the ground that the investigating officer has no territorial jurisdiction.

(3) After investigation is over, if the investigating officer arrives at the conclusion that the cause of action for lodging the FIR has not arisen within his territorial jurisdiction, then he is required to submit a report accordingly under Section 170 of the Criminal Procedure Code and to forward the case to the Magistrate empowered to take cognizance of the offence." (emphasis supplied) 6.

In light of the above, the petition is disposed-of, granting to the petitioner liberty to approach the court of competent territorial jurisdiction, as may be permissible, in accordance with law. 7.

Pending applications, if any, also stand disposed-of. 8.

It is made clear that this court has not expressed any opinion on the merits of the matter.

ANUP JAIRAM BHAMBHANI, J MARCH 25, 2026 ds W.P.(CRL) 908/2026 Page 3 of 3 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.