P Manjunatha v. State of Karnataka
Case brief
What is this about?
Kar HC, CRL.P No. 1922 of 2023, decided 11-11-2025 by M.I. Arun, J.: S.482 Cr.P.C. quashing petition against Magistrate's S.156(3) referral of a private complaint (S.200 Cr.P.C.) filed without first approaching police, contrary to Priyanka Srivastava guidelines; held to be a procedural irregularity per Anurag Bhatnagar, AIR (2025) SC 3427; FIR, investigation and police report in C.C.No.19/2023 allowed to stand; petition dismissed. Keywords: S.156(3), S.200, S.482 CrPC, PCR, procedural irregularity, Hosadurga.
What did the court decide?
Following the Apex Court's ruling in Anurag Bhatnagar (paras 32-35), the learned Magistrate's act in entertaining the private complaint without the petitioner first approaching the jurisdictional police is a procedural irregularity, not an illegality or want of jurisdiction, since the Magistrate was otherwise empowered; it does not vitiate the referral.