Bombay High Court

RENUKA BHOLANATH PATIL AND ORS.versusTHE STATE OF MAHARASHTRA AND ORS.

Decided: 20 February 2026
Disposal: Disposed Off
Bench: A S GADKARI SHYAM C CHANDAK

Holding

The petition is dismissed as moot and the investigating agency is permitted to file a summary report before the magistrate.

Summary

The petitioners filed a criminal writ petition challenging the continuation of the investigation into C.R. No. I-372/2011 and the death of a prime suspect. The State CID submitted a detailed investigation report, including narco‑analysis of four persons and an accidental death report under Section 174 of the Cr.P.C. The investigating agency indicated that no charge‑sheet could be filed and sought to submit a summary report before the jurisdictional magistrate. The Court allowed the agency to file the summary report and held that the petition had become moot. Consequently, the petition was disposed of.

Issues considered

Whether the petition seeking continuation of the investigation should be entertained
Whether the investigating agency may file a summary report before the magistrate in lieu of a charge‑sheet

Legislation cited

Code of Criminal Procedure, 1973 — s. 174

Subjects

criminal procedure
investigation
summary report
magistrate
petition disposal
narco analysis
accidental death report
Section 174 CrPC

Judgment

P. H. Jayani /DTG                                                26 WP3810.2014.doc


                    IN THE HIGH COURT OF JUDICATURE AT BOMBAY
                          CRIMINAL APPELLATE JURISDICTION

                      CRIMINAL WRIT PETITION NO. 3810 OF 2014

Smt. Renuka Bholanath Patil and ors.                         …. Petitioners
      v/s.
The State of Maharashtra and Ors.                            …. Respondents

                          ________________________________

Mr. R.D. Suryawanshi a/w. Ms. Ketkee Kamble for the Petitioners.
Mr. Ajay Patil, APP for the Respondent – State.
Ms. Jayashri Sawant, PI, State CID, Kokanbhavan, Navi Mumbai.
                     ________________________________

                                     CORAM: A.S. GADKARI AND
                                            SHYAM C. CHANDAK, JJ.

                                     DATED : 20th FEBRUARY, 2026.

P. C. :-

1)                  Learned APP tendered across the Bar a detail Report of

Investigation duly signed by Smt. Jayashri Sawant, Police Inspector, State

CID, Navi Mumbai.

1.1)                The various steps adopted in investigating present crime i.e.

C.R.No.I-372/2011 registered with Mahatma Phule Chowk Police Station

including the Narco Analysis Test conducted on four persons, have been

elaborately stated therein. The steps taken in investigation pertaining to

Accidental Death Report No.214/2011 under Section 174 of the Cr.P.C. for

the death of prime suspect namely Jitendra Ramdas Patil are also stated in

the said Report.


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P. H. Jayani /DTG                                                  26 WP3810.2014.doc


1.2)                It is stated that, after putting her substantial efforts in last

many years, nothing is revealed to file charge-sheet against a particular

accused person and therefore the Investigating Agency will be filing

‘A-Summary Report’ before the concerned Court. She tendered across the

bar a photocopy of the said Summary Report to be filed before the

jurisdictional Magistrate. The said Report is taken on record.

2)                  We permit the Investigating Agency to file respective

‘A-Summary Reports’ before the jurisdictional Magistrate.

3)                  In view of the above, we are of the opinion that, keeping the

Petition pending further is of no avail and is accordingly disposed off.



      (SHYAM C. CHANDAK, J.)                             (A.S. GADKARI, J.)




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