The Supreme Court of India has held that a High Court, while exercising its testamentary jurisdiction, does not cease to be a Constitutional Court of record and retains its inherent and plenary powers to direct a court-monitored criminal investigation to safeguard an estate in custody of the court (in custodia legis) from being plundered. A
High Court Sitting in Testamentary Jurisdiction Retains Plenary Powers to Order Criminal Investigation to Protect Estate ‘In Medio’: Supreme Court
