Disposed¶101

Macharaja v. The State of Tamilnadu

Madras HC11 Nov 2025CRL OP(MD)/12922/2025

Case brief

AI extract

What is this about?

FIR quashing declined as final report taken on file; e-filing of charge sheets/final reports; Rule 25(6) Criminal Rules of Practice prohibits return of final reports, memorandum to IO; Section 528 BNSS; Athachi; Form 91; C.C.No.107 of 2025; Judicial Magistrate Vilathikulam; Crime No.156 of 2020; Soorangudi Police Station, Thoothukudi; High Court Notification ROC.No. 75085A/2023/Comp3 dated 24.08.2023; CCTNS; CNR number; defect rectification drive; monthly review; Registrar (Judicial) monitoring; Registry staff training.

What did the court decide?

No relief on the prayer to quash the FIR; petition disposed of with observations and systemic directions on e-filing and streamlining of final reports ¶101

Macharaja Vs The State of Tamilnadu — Madras HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

No relief on the prayer to quash the FIR; petition disposed of with observations and systemic directions on e-filing and streamlining of final reports

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Issue for consideration

Whether the FIR in Crime No.156 of 2020 registered against the petitioner should be quashed. +2 more

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Court's answer

Since the final report had already been filed and taken on file, the Court was not inclined to entertain the petition for quashing the FIR without ascertaining the materials in the final report; it is for the petitioner to challenge the final report, if so advised.

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Ratio / Principle

Returning the final report for non-filing of Athachi and Form 91, instead of retaining it on file and issuing a memorandum to the Investigating Officer to rectify the defect (with escalation to superior police officers), is contrary to Rule 25(6) of the Criminal Rules of Practice.

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Key takeaways

Acceptance of physical re-submission of the final report, despite e-filing of charge sheets having been made mandatory throughout Tamil Nadu and Puducherry, is inconsistent with the Standard Operating Procedure and defeats the object of digitisation.ratio¶36
Filing of error-free final reports is a mandatory responsibility of Investigating Officers, and departmental instructions on procedural compliance must be followed strictly to avoid technical delays.obiter¶41
Directions: the solutions and best practices evolved during the one-time defect-rectification exercise shall be implemented in letter and spirit across all districts, with monthly review meetings by Heads of Departments and Judicial Officers and reports forwarded to the Registrar (Judicial) of the Bench for monitoring.

Detailed headnote1 paragraphs

Quashing of FIR declined where final report already filed and taken on file — Madras High Court (Madurai Bench) disposed of a petition under S.528 BNSS seeking quashing of FIR in Crime No.156 of 2020 (Soorangudi Police Station, Thoothukudi), noting the final report was e-filed before the Judicial Magistrate, Vilathikulam on 27.11.2024, returned twice for want of Athachi and Form 91, re-submitted on 30.07.2025 after rectification, and taken on file on 01.08.2025 as C.C.No.107 of 2025; petitioner left free to challenge the final report. Held that returning final reports for curable defects contravenes Rule 25(6) of the Criminal Rules of Practice, which mandates a memorandum to the Investigating Officer with escalation to superior officers, and that acceptance of physical re-submission is inconsistent with the e-filing SoP under the High Court Notification ROC.No. 75085A/2023/Comp3 dated 24.08.2023 making e-filing of charge sheets mandatory. The Court recorded the results of a one-time district-wise rectification drive (e-filed final reports rising from 4,27,204 to 4,62,680 as on 07.10.2025) and directed implementation of the evolved best practices across all districts, monthly review meetings with reports to the Registrar (Judicial) of the Bench, and structured training for District Registry staff under High Court supervision.

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Crl.O.P.(MD)No.12922 of 2025

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BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

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RESERVED ON : 29.08.2025

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PRONOUNCED ON : 11.11.2025

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CORAM :

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THE HON`BLE MR.JUSTICE B.PUGALENDHI

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Crl.OP(MD)No.12922 of 2025

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Macharaja ... Petitioner

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1.The State of Tamil Nadu, Rep. by The Inspector of Police, Soorangudi Police Station, Thoothukudi District.

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2.Thangapandi

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...Respondents

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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.

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For Petitioner : Mr.N.Suriyamuthu For R1 : Mr.T.Senthil Kumar Additional Public Prosecutor

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Mr.P.Kottaichamy

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Government Advocate (Crl.side)

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1/12

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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O R D E R

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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.

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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.

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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.

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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

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2/12

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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months. Therefore, by order dated 01.08.2025, this Court called for a report from the learned Judicial Magistrate, Vilathikulam, explaining the delay.

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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.

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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

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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complied within three months. The procedure adopted in the present case is therefore contrary to the said Rule.

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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.

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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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4/12

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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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.

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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.

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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.

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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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.

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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:-

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(i) Lack of internet connectivity in police stations;

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(ii) Non-utilisation of scanners and improper file compression;

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(iii) Duplicate filings instead of defect correction;

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(iv) Data entry errors and missing signatures;

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(v) Non-submission of sufficient document copies.

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The following corrective measures were proposed:-

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(i) Ensure proper internet facilities in all police stations;

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(ii) IO/SHO must verify and attest the report before e-filing;

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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(iii) Remove duplicate e-filings and correct returned cases;

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(iv) Record e-filing / CNR numbers in the CCTNS and registers;

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(v) Utilize OCR-format scanning and avoid file compression beyond

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limits;

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(vi) Submit sufficient copies post-numbering;

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(vii) Correct court objections promptly, failing which disciplinary action may follow;

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(viii) Update CCTNS to prevent duplication.

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B) Common Issues on the Judicial Side:-

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(i) Non-issuance of filing numbers;

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(ii) Unnecessary returns of charge sheets;

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(iii) Over-reliance on physical copies for scrutiny;

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(iv) Lack of proper scrutiny and unattended re-submitted e-files.

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The following remedial steps were formulated:-

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(i) All e-filed cases must be assigned filing/CNR numbers;

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(ii) Physical documents shall not be insisted upon at filing stage;

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(iii) Explore centralised scrutiny teams in CJM establishments;

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(iv) Delete duplicate filings;

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7/12

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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(v) Raise objections only after assigning filing number;

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(vi) Ensure proper FIR register maintenance;

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(vii) Timely collection of case property;

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(viii) Monthly reports on pending objections (over 3 months) to be sent to respective SPs/Commissioners.

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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

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under:-

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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 o reports for no filing n has been genera	f final which umber been ted	Total Number of e-filed final reports pending for Scrutiny	Numbe e-filed f reports re without pr filing num CIS soft	r of inal jected oviding ber in ware
Kanyakumari	4638	2004	Before exercise	273	983	Before 06.08.2025	1234
			After exercise	54	32	After 06.08.2025	0
Tirunelveli	3869	2781	Before exercise	458	1002	Before 06.08.2025	8542
			After exercise	144	1265	After 06.08.2025	109

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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			Before	365	2978	Before	6225
Thoothukudi	6574	1254	exercise After exercise	61	349	06.08.2025 After 06.08.2025	155
Tenkasi	3154	1173	Before exercise	4	75	Before 06.08.2025	3715
			After exercise	0	0	After 06.08.2025	21
Virudunagar	6101	485	Before exercise	3753	7046	Before 06.08.2025	5832
			After exercise	283	500	After 06.08.2025	436
Madurai	7446	594	Before exercise	381	1115	Before 06.08.2025	3272
			After exercise	82	627	After 06.08.2025	48
Ramanatha-	4153	1175	Before exercise	204	1477	Before 06.08.2025	1181
puram			After exercise	119	172	After 06.08.2025	21
Sivagangai	3796	628	Before exercise	462	1742	Before 06.08.2025	1304
			After exercise	83	58	After 06.08.2025	71
Theni	4694	283	Before exercise	449	2388	Before 06.08.2025	1938
			After exercise	162	109	After 06.08.2025	56
Dindugul	2780	24	Before exercise	750	1259	Before 06.08.2025	4401
			After exercise	66	161	After 06.08.2025	43
Karur	2115	1775	Before exercise	184	54	Before 06.08.2025	1142
			After exercise	41	58	After 06.08.2025	0
Trichy	7559	305	Before exercise	432	812	Before 06.08.2025	3469
			After exercise	100	211	After 06.08.2025	42
			Before	186	837	Before	3107
Pudukottai	1727	3591	exercise			06.08.2025
			After exercise	48	109	After 06.08.2025	0

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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			Before	516	18074	Before	5019
Thanjavur	7178	8989	exercise			06.08.2025
			After	117	280	After	165
			exercise			06.08.2025
			Before	8417	39842	Before	54782
Total	68564	23828	exercise			06.08.2025
			After	1360	3931	After	1210
			exercise			06.08.2025

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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.

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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.

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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. 10/12

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https://www.mhc.tn.gov.in/judis

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Crl.O.P.(MD)No.12922 of 2025

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With the above observations and directions, this Criminal Original

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Petition stands disposed of.

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NCC : Yes/No 11.11.2025 Index : Yes/No Internet : Yes gk

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Note: