Taking note of the fact that a muslim man was allegedly beaten, made to chant ‘Jay Shriram’, and the video of the same was made viral over social media, the Orissa High Court has ordered that the investigation of the case should be assigned to a Senior Officer not below the rank of the post of DSP/SDPO.

The High Court was considering a petition whereby the petitioner sought a direction to the opposite parties to hand over the investigation of the case to the Crime Branch or form a Special Investigation Team (SIT) and Sections 111, 299, 302, 117(4) of BNS be added against the accused persons, along with the provisions already in the FIR.

The Single Bench of Justice Savitri Ratho held, “The investigation in the case is in progress, but keeping in view the nature of the allegations and as it is not disputed that the incident had been videographed and made viral over social media, in the opinion of the Court that it would be proper if the investigation of the case is supervised by a Senior Officer not below the rank of DSP.”

“As the Petitioner is the father of the injured, even though he is not the informant, I am inclined to entertain the CRLMP”, it added.

Advocate P.R. Chhatoi represented the Petitioner, while Additional Standing Counsel Sarathi Jyoti Mohanty represented the Respondent.

Factual Background

The petitioner alleged that his son had been assaulted by the accused persons and they had removed his clothes, dragged him on the surface naked and made him mock on the road, forcing him to utter “Jay Sriram Jay Sriram” although he belongs to the Muslim community. This incident was recorded on mobile and made viral on social media. The video recording was sent to the mobile of the I.I.C. Bahalda Police Station, and the FIR was registered after the video became viral. It was the petitioner’s case that the video in question became viral on January 4, 2026, and an FIR had been registered for the offences under Sections 126(2), 296, 155(2), 117(2), 133, 351(3), 3(5) of BNS. However, Sections 111, 299, 302, and 117(4) of the BNS were not added.

Reasoning

Considering that the investigation in the case was in progress and noting that the incident had been made viral over social media, the Bench held that it would be proper if the investigation of the case was supervised by a Senior Officer not below the rank of DSP.

The Bench further took note of the fact that although the FIR was registered under Section 117(2) of the BNS, while forwarding the accused persons, the said Section has been dropped.

Entertaining the Petition, the Bench directed that a Senior Officer not below the rank of the post of DSP / SDPO should supervise the investigation of the case and ensure that the investigation is conducted fairly.

Cause Title: Sk. Hanif v. State of Odisha (Case No.: CRLMP No. 283 of 2026)

Appearance

Petitioner: Advocate P.R. Chhatoi

Respondent: Additional Standing Counsel Sarathi Jyoti Mohanty

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Orissa High CourtJustice Savitri Ratho

Tulip Kanth

Assistant Editor

Tulip Kanth is an Assistant Editor at Verdictum having over 5 years of experience in the field of legal journalism and editing. She extensively covers judgments of the Supreme Court, High Courts as well as Tribunals. She has previously worked with a legal publishing website where she oversaw the work of other editors and has also created updates on notifications of different Government Ministries. She holds an English Honours Degree from SGTB Khalsa College, Delhi University and has completed her LLB course with specialisation in Corporate Law from Amity University.