Summary
A CBI investigation into transfers of a religious trust’s land was set aside. The High Court had treated deity property as incapable of transfer, made unsupported fraud findings on disputed facts, and relied on sweeping allegations against government functionaries. Statutory provisions contemplated sanctioned transfers, and the dispute over trustees’ powers was civil. Exceptional circumstances and sufficient prima facie material, rather than allegations alone, were necessary for a court-directed CBI inquiry.
Issues
- Whether the religious-trust land dispute justified a court-directed CBI investigation.
- Whether allegations against government functionaries and disputed transfer approvals supplied sufficient grounds.
Held
- The High Court should have refrained from entertaining this public-interest petition over alleged wrongful transfers of religious property. It improperly returned fraud findings on disputed facts, without any prior complaint to police or public authorities. (¶¶ 8–10, 19)
- The assertion that deity land could never be transferred was untenable: the applicable statutory scheme contemplated transfers with prescribed approvals, which the trustees claimed to have obtained. Official permission alone did not disclose a criminal offence. (¶¶ 11, 19)
- Constitutional power to direct a CBI inquiry must be exercised sparingly in exceptional situations on sufficient prima facie material. Allegations against the State or its functionaries alone did not justify bypassing ordinary investigation. (¶ 12–20)
- This dispute concerned trustees’ rights to sell religious-trust property and gave rise to a civil dispute. The High Court had misdirected itself in ordering the CBI to investigate. (¶ 21–22)
Result
Appeal allowed. High Court order directing CBI investigation set aside; public-interest writ petition dismissed.