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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
- Section Magistrate supervision
Practitioner takeaway
Magistrate can order further investigation; complements §156(3) jurisdiction.
Citation
- Citation: (2019) 17 SCC 1
- Court: Supreme Court of India
- Date: 2019-10-16
- Outcome: disposed
- Reporter / Cause-list: (2019) 17 SCC 1
Related
Last reviewed: 23 April 2026.

Discussion