The Uttarakhand High Court has directed the transfer of two vigilance cases against a former Director of the Corbett Tiger Reserve and other senior forest officials to the Special Judge, Anti-Corruption, CBI, Dehradun, holding that the designated CBI Court alone has jurisdiction to try cases investigated by the Central Bureau of Investigation. The Court observed that once the CBI had completed its investigation and filed its charge-sheet before the notified CBI Court, continuation of parallel proceedings before the Special Judge, P.C. Act, would result in jurisdictional inconsistency.

Justice Siddhartha Sah was hearing an application filed by the Central Bureau of Investigation under Section 447 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking transfer of two criminal cases pending before the Special Judge, P.C. Act, to the Court of the Special Judge, Anti-Corruption, CBI, Dehradun. The CBI submitted that pursuant to the High Court's earlier directions in a public interest litigation, it had re-registered the vigilance case, completed the investigation, and filed a comprehensive charge-sheet before the Special CBI Court against several public servants, including the then Director of Corbett Tiger Reserve, for offences under the IPC, Prevention of Corruption Act, Forest (Conservation) Act, Indian Forest Act, and Wildlife (Protection) Act.

The CBI contended that all documents from the vigilance proceedings had already been supplied to it and that the final report under Section 173(2) CrPC had been filed before the Special Judge, Anti-Corruption, CBI, Dehradun, which was the notified court for trying CBI cases. It therefore sought transfer of the pending vigilance trials to avoid procedural inconsistencies and jurisdictional conflicts.

Accepting the submission, the Court held that the transfer sought was purely formal in nature since the CBI charge-sheet had already been filed before the competent Special CBI Court. It observed that the Special Judge, Anti-Corruption, CBI, Dehradun, alone possessed jurisdiction to try cases investigated by the CBI and that allowing the proceedings to continue before the Special Judge, P.C. Act, Haldwani, would not be in consonance with the jurisdiction vested in the CBI Court.

Accordingly, the Court allowed the transfer application and directed that Misc. Criminal Case No. 01 of 2023 and Misc. Criminal Case No. 22 of 2023 be transferred from the Court of the Special Judge, P.C. Act, Kumaon Region, Haldwani, to the Court of the Special Judge, Anti-Corruption, CBI, Dehradun, for disposal in accordance with law.

Case Title: Central Bureau of Investigation v. State of Uttarakhand & Ors. [Criminal Misc. Application No. 25 of 2025]

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