The Madurai Bench of the Madras High Court, while disposing of a petition to quash a First Information Report (FIR), identified significant procedural illegalities and systemic failures in the handling of e-filed final reports (charge sheets) by subordinate courts. Justice B. Pugalendhi found the status of e-filed reports to be “alarming” and, after initiating a successful one-time coordinated drive to clear backlogs, issued a series of binding directions to both the police and the judiciary to streamline the mandatory e-filing process.
The matter, Crl.O.P.(MD)No.12922 of 2025, was initiated by a petitioner, Macharaja, seeking to quash Crime No.156 of 2020 registered by the Soorangudi Police Station, Thoothukudi District.
Case Background and Procedural Lapses
During a hearing on 01.08.2025, the prosecution submitted that the investigation was complete and the final report had been filed via e-filing on 27.11.2024. However, it had not been taken on file. The Court, observing it was for the petitioner to challenge the final report, was “not inclined to entertain the petition for quashing the FIR.”
However, the Court noted the eight-month delay in the report being numbered. A report from the learned Judicial Magistrate, Vilathikulam, revealed the e-filed report was “returned on 06.12.2024” for non-uploading of “Athachi and Form 91.” The Investigating Officer then re-submitted the report physically on 15.04.2025. This was again returned for a missing Athachi before finally being taken on file on 01.08.2025.
Court’s Analysis: Violation of Rules and Defeat of Digitisation
Justice B. Pugalendhi’s order, pronounced on 11.11.2025, held that this procedure was contrary to established law. The Court found that the Magistrate’s act of returning the final report was in direct violation of Rule 25(6) of the Criminal Rules of Practice. The judgment stated this rule “specifically prohibits the return of final reports and directs that a memorandum should be issued to the Investigating Officer to rectify the defect.”
Furthermore, the Court found that the mandatory e-filing notification (ROC.No. 75085A/2023/Comp3 dated 24.08.2023) was flouted. “Acceptance of physical resubmission, as in the present case, is inconsistent with the said procedure and defeats the very object of digitisation,” the order read.
Systemic Failures and Coordinated Rectification Drive
Upon seeking particulars from all districts under its jurisdiction, the Court found an “alarming” situation with “several mismatch, not taken on file, etc.”
This prompted the Court to initiate a “coordinated one-time exercise” over one month. This drive involved joint teams of police officials and Registry staff of Magistrate Courts, with weekly review meetings attended by Chief Judicial Magistrates, Commissioners and Superintendents of Police, and representatives from the Inspectors General of Police, South and Central Zones. A System Analyst from the High Court was deputed to each district to provide technical training and resolve issues.
The Court identified common issues on both sides.
Police Side Issues:
- Lack of internet connectivity in police stations.
- Duplicate filings instead of defect correction.
- Data entry errors and improper file compression.
- Non-submission of sufficient document copies.
Judicial Side Issues:
- “Unnecessary returns of charge sheets.”
- Non-issuance of filing numbers upon e-filing.
- Over-reliance on physical copies for scrutiny.
- Lack of proper scrutiny and unattended re-submitted e-files.
Results and Final Directions
The Court noted the exercise showed “measurable improvement.” A comparative table demonstrated that for the districts under the Bench’s jurisdiction, the “Total Number of e-filed final reports pending for Scrutiny” dropped from 39,842 (as of 06.08.2025) to 3,931 (as of 07.10.2025). The number of reports “rejected without providing filing number” fell from 54,782 to 1,210 in the same period.
The Court recorded its “appreciation of the coordinated efforts of the judiciary and police officials.”
Disposing of the original quash petition, the Court issued the following directions:
- The solutions and best practices evolved during the drive “shall be implemented in letter and spirit across all districts.”
- Monthly review meetings shall be convened by concerned Heads of Departments and Judicial Officers to ensure continuous compliance, with reports forwarded to the Registrar (Judicial) of the Bench.
- The Court suggested that District Registry staff be “imparted with structured training under the supervision of the High Court” to ensure uniform procedures.
The order was directed to be communicated to the Director General of Police, the Registrar General of the Madras High Court, and all relevant police and judicial heads within the Bench’s jurisdiction.
