Macharaja v. The State Of Tamilnadu
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT RESERVED ON : 29.08.2025 PRONOUNCED ON : 11.11.2025 CORAM :
THE HON`BLE MR.JUSTICE B.PUGALENDHI Crl.OP(MD)No.12922 of 2025 Macharaja ... Petitioner Vs 1.The State of Tamil Nadu, Rep. by The Inspector of Police, Soorangudi Police Station, Thoothukudi District.
2.Thangapandi
...Respondents
Prayer: Criminal Original Petition filed under Section 528 of BNSS, to call for the records in Crime No.156 of 2020 on the file of the first respondent and quash the same.
For Petitioner : Mr.N.Suriyamuthu For R1 : Mr.T.Senthil Kumar Additional Public Prosecutor Mr.P.Kottaichamy Government Advocate (Crl.side) ***** 1/12
O R D E R
The petitioner, one of the accused in Crime No.156 of 2020 on the file of the first respondent Police, has filed this Criminal Original Petition seeking to quash the First Information Report registered against him. 2.When the matter came up for hearing on 01.08.2025, the learned Government Advocate (Crl. Side) submitted that the investigation in Crime No.156 of 2020 had already been completed and that the final report had been filed through e-filing before the learned Judicial Magistrate, Vilathikulam, on 27.11.2024. However, it was yet to be taken on file. 3.Since it was represented that the final report had already been filed, this Court was not inclined to entertain the petition for quashing the FIR without ascertaining the materials relied upon by the Investigating Agency in the final report. It is for the petitioner to challenge the final report, if so advised.
4.At the same time, it was noticed that though the final report had been filed in November 2024, it had not been taken on file for over eight 2/12
months. Therefore, by order dated 01.08.2025, this Court called for a report from the learned Judicial Magistrate, Vilathikulam, explaining the delay. 5.Pursuant to the said direction, the learned Judicial Magistrate has submitted a report stating that the final report was filed through e-filing on 27.11.2024. However, Athachi and Form 91 were not uploaded, as a result of which the final report was returned on 06.12.2024. Thereafter, the Investigating Officer re-submitted the final report physically on 15.04.2025. Even in this resubmission, the Athachi was not enclosed, which was communicated to the Investigating Officer vide letter dated 05.06.2025. After rectifying the defects, the Investigating Officer re-submitted the final report on 30.07.2025 and it was finally taken on file on 01.08.2025 in C.C.No.107 of 2025.
6.On perusal of the report, it appears that the final report was returned on account of non-filing of Athachi and Form 91, instead of being retained on file and the defect communicated separately. Rule 25(6) of the Criminal Rules of Practice specifically prohibits the return of final reports and directs that a memorandum should be issued to the Investigating Officer to rectify the defect, with escalation to superior police officers if not 3/12
complied within three months. The procedure adopted in the present case is therefore contrary to the said Rule.
7.The Madras High Court, by Notification in ROC.No. 75085A/2023/Comp3 dated 24.08.2023, has made e-filing of charge sheets mandatory throughout Tamil Nadu and Puducherry. The Standard Operating Procedure (SoP) prescribes that defects should be communicated electronically and that rectification must also be carried out through the e-filing portal. Acceptance of physical resubmission, as in the present case, is inconsistent with the said procedure and defeats the very object of digitisation.
8.This Court has, therefore, sought for the particulars with regard to the e-filed final reports and its status, for the Districts coming under the jurisdiction of this Bench. The particulars produced before this Court is alarming with several mismatch, not taken on file, etc., During the hearing, certain practical difficulties in the e-filing process were also brought to the notice of this Court, particularly relating to defect rectification and re-uploading.
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9.The filing of error-free final reports is a mandatory responsibility of Investigating Officers. Several circulars issued by the Police Department emphasize the necessity of procedural compliance before filing the final report. There is no second thought that these instructions must be followed strictly to avoid unnecessary technical delays. 10.In order to address the pendency of final reports that remained untaken on file due to curable defects, this Court initiated a coordinated one-time exercise as an interim measure, for the Districts coming under the jurisdiction of this Bench. A joint team of police officials and the Registry staff of Magistrate Courts held meetings at the district level, identified such pending final reports, and carried out defect rectifications. 11.
This exercise was conducted over one month, during which weekly review meetings were convened by this Court through video conferencing with the participation of Chief Judicial Magistrates, Commissioners and Superintendents of Police, of the Districts coming under the jurisdiction of this Bench and representatives from the Offices of the Inspectors General of Police, South and Central Zones.
12.During this drive, a System Analyst from the High Court was deputed to each District coming under the jurisdiction of this Bench to coordinate between the Police and the District Courts, to train personnel, resolve technical issues, and ensure that all stakeholders understood the e-filing process uniformly. This field-level support substantially reduced confusion and facilitated defect rectification. 13.During the course of the drive, the following issues along with its solutions were identified on the side of police as well as District Judiciary. A) Common Issues on the Police Side:- (i) Lack of internet connectivity in police stations; (ii) Non-utilisation of scanners and improper file compression; (iii) Duplicate filings instead of defect correction; (iv) Data entry errors and missing signatures; (v) Non-submission of sufficient document copies. The following corrective measures were proposed:- (i) Ensure proper internet facilities in all police stations; (ii) IO/SHO must verify and attest the report before e-filing; 6/12
(iii) Remove duplicate e-filings and correct returned cases; (iv) Record e-filing / CNR numbers in the CCTNS and registers; (v) Utilize OCR-format scanning and avoid file compression beyond limits;
(vi) Submit sufficient copies post-numbering; (vii) Correct court objections promptly, failing which disciplinary action may follow;
(viii) Update CCTNS to prevent duplication.
B) Common Issues on the Judicial Side:- (i) Non-issuance of filing numbers;
(ii) Unnecessary returns of charge sheets;
(iii) Over-reliance on physical copies for scrutiny; (iv) Lack of proper scrutiny and unattended re-submitted e-files. The following remedial steps were formulated:- (i) All e-filed cases must be assigned filing/CNR numbers; (ii) Physical documents shall not be insisted upon at filing stage; (iii) Explore centralised scrutiny teams in CJM establishments; (iv) Delete duplicate filings;
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(v) Raise objections only after assigning filing number; (vi) Ensure proper FIR register maintenance;
(vii) Timely collection of case property;
(viii) Monthly reports on pending objections (over 3 months) to be sent to respective SPs/Commissioners.
14.The district-wise progress during this drive has shown measurable improvement. Prior to the exercise, for the Districts coming under the jurisdiction of this Bench, the total number of final reports filed through e-filing was 4,27,204, which has risen to 4,62,680 as on 07.10.2025, reflecting active follow-up and rectification of procedural lapses. A comparative position of e-filed charge sheets as on 06.08.2025 and 07.10.2025, is as under:- District Number of cases renumbered by identifying defects during course of the exercise Number of cases closed / identified as duplicate during the exercise after issuing CNR number Number of final reports for which no filing number has been been generated Total Number of e-filed final reports pending for Scrutiny Number of e-filed final reports rejected without providing filing number in CIS software Kanyakumari Before exercise Before 06.08.2025 After exercise After 06.08.2025 Tirunelveli Before exercise Before 06.08.2025 After exercise After 06.08.2025 8/12
Thoothukudi Before exercise Before 06.08.2025 After exercise After 06.08.2025 Tenkasi Before exercise Before 06.08.2025 After exercise After 06.08.2025 Virudunagar Before exercise Before 06.08.2025 After exercise After 06.08.2025 Madurai Before exercise Before 06.08.2025 After exercise After 06.08.2025 Before exercise Before 06.08.2025 Ramanathapuram After exercise After 06.08.2025 Sivagangai Before exercise Before 06.08.2025 After exercise After 06.08.2025 Theni Before exercise Before 06.08.2025 After exercise After 06.08.2025 Dindugul Before exercise Before 06.08.2025 After exercise After 06.08.2025 Karur Before exercise Before 06.08.2025 After exercise After 06.08.2025 Trichy Before exercise Before 06.08.2025 After exercise After 06.08.2025 Pudukottai Before exercise Before 06.08.2025 After exercise After 06.08.2025 9/12
Thanjavur Before exercise 18074 Before 06.08.2025 After exercise After 06.08.2025 Total 68564 23828 Before exercise 39842 Before 06.08.2025 54782 After exercise After 06.08.2025 15.This Court records its appreciation of the coordinated efforts of the judiciary and police officials in streamlining the e-filing of final reports. The exercise demonstrates the positive outcomes achievable through sustained monitoring and inter-departmental cooperation. 16.The solutions and best practices evolved during this exercise shall be implemented in letter and spirit across all districts. Monthly review meetings shall be convened by the concerned Heads of Departments and Judicial Officers to ensure continuous compliance. Reports of such reviews shall be forwarded to the Registrar (Judicial) of this Bench for monitoring. 17.
This Court also suggests that the District Registry staff who are handling e-filing of charge sheets shall be imparted with structured training under the supervision of the High Court, so that uniform procedures and digital handling practices are followed across all districts.
With the above observations and directions, this Criminal Original Petition stands disposed of.
NCC : Yes/No 11.11.2025 Index : Yes/No Internet : Yes gk Note:
Registry is to communicate this order to
1. The Principal District Judges and Chief Judicial Magistrates of all Districts coming within the jurisdiction of this Bench;
2. The Commissioners of Police / Superintendents of Police of all Cities / Districts coming within the jurisdiction of this Bench;
3. The Inspector Generals of Police, South and Central Zones, Tamil Nadu;
4. The Registrar General, Madras High Court;
5. The Director General of Police, Chennai.
To The Inspector of Police, Soorangudi Police Station, Thoothukudi District.
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B.PUGALENDHI,J., gk Crl.OP(MD)No.12922 of 2025 11.11.2025 12/12