Mathampaty case transfer the investigation in Crime No.179 of 2025, dated 08-10-2025, on the file of the 2nd Respondent to the 3rd Respondent, i.e., Additional Director General of Police, CBCID, Chennai, or any other independent

MEMORANDUM OF CRIMINAL ORIGINAL PETITION
FILED UNDER SECTION 528 OF BHARATIYA NAGARIK
SURAKSHA SANHITA,2023

IN THE HIGH COURT OF JUDICATURE AT MADRAS
CRL. O.P. No. OF 2025 in
Crime No. 179 of 2025
(On the file of Assistant Commissioner of Police, CCB-I, Chennai-CCB)

Joy (F/A. 37 Yrs)
W/o. Madhampatty Rangaraj,
Flat No.3F4, 3rd Floor,
Baashyam Plutus Residence,
Door No.32, L.B. Road,
Thiruvanmiyur, Chennai- 600 041.

… Petitioner/Defacto Complainant

V/s 1. Commissioner of Police, Greater Chennai Police,
No.132, E.V.K. Sampath Road, Vepery, Chennai-600 007.

2. The State rep by the
Assistant Commissioner of Police,
CCB-I, Chennai-CCB District, Chennai.
… 1st & 2nd Respondents/Complainant

3. The State Rep by
Additional Director General of Police, CBCID., Chennai District.
…. 3rd Respondent

TRANSFER PETITION FILED UNDER SECTION 528 OF B.N.S.S, 2023.
The Petitioner most humbly submits as follows:

1. The address for service of all notices and process on the Petitioner is that of her advocates M/s. R. Sudha, R.V. Dinesh Kumar, M. Mathan Raj, S. Saravanan & A.P. Sachithanantham, Advocates having office at No.6, “CHENNAI HOUSE”, Annex Building 3rd Floor, Esplanade, Broadway, Chennai – 600 104.

2. The address for service of all notices and processes on the Respondent is as stated above.

3. The Petitioner above named beg to present this Memorandum of Criminal Original Petition and prays that this Hon’ble Court may be pleased to transfer the investigation in Crime No.179 of 2025, dated 08-102025, on the file of the 2nd Respondent, i.e., Central Crime Branch-I, Chennai (CCB), to the 3rd
Respondent, i.e., Additional Director General of
Police, CBCID, Chennai, or any other independent agency for the following among other reliefs.

CASE OF THE PETITIONER

4. It is most humbly submitted that the Petitioner was residing at the aforesaid address along with the accused, Madhampatty Rangaraj, her son Jayden, and her visually impaired mother prior to the present issue. The Petitioner is a reputed costume designer and has been popularly known in her field for over a decade.

5. It is most humbly submitted that in the year 2018, she married one Mr. J.J. Fredrick. However, the marriage was fraught with matrimonial issues, and consequently, in 2020, they separated and began living apart. In July 2023, through a mutual friend, the Petitioner became acquainted with the accused,
Madhampatty Rangaraj and between 01-08-2023 and 30-08-2023, they met on several occasions, and their friendly acquaintance turned into a relationship. During those meetings, the accused informed the Petitioner that he had judicially separated from his first wife, Mrs. Shruthi, and was living separately. He expressed his desire for an understanding life partner and implored the Petitioner to come out of her troubled matrimonial life, as she had explained the disharmony and mental agony she suffered. The accused comforted her, moved closely with her, and asked her to divorce her husband so that they could marry and begin a new life together.

6. It is most humbly submitted that thereafter, the accused, Madhampatty Rangaraj, frequently visited Chennai and took the Petitioner to various hotels, spending private time with her. He insisted that she initiate divorce proceedings and warned that any delay would hinder their marriage. Out of love and affection, the Petitioner filed a divorce petition before the jurisdictional court at Chennai and obtained a decree of divorce from her first husband.

7. It is most humbly submitted that, the accused Madhampatty Rangaraj had stated that he was in love with the Petitioner and proposed for marriage. Accordingly, on 24th December, 2023 in the presence of his friends and company staffs, the accused and the Petitioner got married at “Thiruveedhi Amman Temple” situated at M.R.C. Nagar, Chennai and following their marriage which was solemnized as per Hindu Rites and Customs, the Petitioner and the accused had started their matrimonial life at Chennai.

8. It is most humbly submitted that subsequent to the marriage, the Petitioner accompanied the accused to various functions and significant occasions as his wife. He also took her on an international trip to Dubai and other places to celebrate their new life. During these occasions, the accused introduced the Petitioner to everyone as his wife.

9. It is most humbly submitted that, the Petitioner and the accused Madhampatty Rangaraj started their matrimonial life peacefully in a Flat rented by him at Thiruvanmiyur and both have lived in the said flat as husband and wife, in these circumstances, in the month of May,2024 the accused Madhampatty Rangaraj took the Petitioner to his native place Coimbatore for the very first time and introduced her to his parents. As the relationship was going smoothly, in the month of June,2024 the accused got Petitioner’s son Jayden admitted to a prestigious school and in the process of admission he signed as the father of the petitioner’s son.

10. It is most humbly submitted that, in the month of September, 2024, the Petitioner became pregnant due to her intimacy with the accused Madhampatty Rangaraj and when the Petitioner informed about the pregnancy to him, he blackmailed her and forced her into an abortion, however, due to her love for him, the Petitioner underwent the turmoil and mental agony of abortion. Subsequent to the said incident, in the month of October,2024, the accused again took her to his native place in Coimbatore for their first Deepavali after marriage, as a newly married couple, she had gifted his parents and his brother new dresses owing to the occasion. While so, once again the Petitioner became pregnant in the month of December,2024 and when she happily informed about the pregnancy to the accused Madhampatty
Rangaraj, he started abusing her and unnecessarily created quarrels with the Petitioner and once again he forced her to abort the pregnancy despite the petitioner’s continuous objection, the accused forced the petitioner into abortion and due to the same, her health deeply deteriorated, however, due to her highest love and affection towards him, she was silently enduring those difficult situations.

11. It is most humbly submitted that, once again, subsequent to the abortion, the accused Madhampatty Rangaraj became intimate with the Petitioner, and in the month of April 2025, she again became pregnant. Even this time, he forced her to abort the child, but the Petitioner firmly refused and objected to his demand for an abortion, requesting him to nurture this child and informing him that continuous abortions could be detrimental to her health and life. However, the accused Madhampatty Rangaraj did not heed her request, and whenever he got an opportunity, he insisted on aborting the baby.
This abusive conduct of the accused continued for a while, and during late April 2025, he became very abusive and started physically assaulting the
Petitioner, demanding that she should abort the child. In one such occasion, the accused physically assaulted the Petitioner, and as a result, she suffered injuries in her left ear, her eardrum was ruptured, and she also developed serious vision problems. Further, this abusive character of the accused Madhampatty Rangaraj became intolerable, and he damaged her iPhone and iPad, which contained all the photographs and videos they took on various occasions after their meeting, including special occasions.

12. It is most humbly submitted that, subsequent to these incidents, the accused avoided coming to the Petitioner’s home. One day, he came to their residence and took her phone, saying he would get it repaired. Believing him, the Petitioner gave her phone. However, after taking her phone, the accused did not return it, and when she requested the phone back, he returned it after a quarrel. When she checked the phone, the Petitioner found that the accused had deleted all the data, including photographs and videos taken during their marriage and relationship. The said photos and videos were proof of their happy life; however, the accused, with dishonest intention and mala fide intent to cheat the Petitioner, deleted all the data on her phone by deceiving her under the pretext of repairing it.

13. It is most humbly submitted that, subsequent to the aforesaid incidents, the accused Madhampatty Rangaraj frequently created unnecessary quarrels with the Petitioner and began emotionally blackmailing her by asking her whether she wanted to have the baby or continue the matrimonial life with him. Further, the accused threatened her that unless she aborts the child, he could end the matrimonial life between them and would leave her at lurch. Shocked by his abusive conduct, the Petitioner became emotionally shattered and weakened and, she realized that this sudden change was due to the influence of his friends, family, and close associates who claimed to be his well-wishers, such as Mr. Arun Babu.

14. It is most humbly submitted that, as the Petitioner did not heed his emotional blackmail and abusive nature, the accused began to completely avoid and deserted her, no longer coming to their residence. Therefore, to meet him, the Petitioner went to the shooting premises where the accused Madhampatty Rangaraj
was participating in a television programme namely “Cook with Comali.” At that place, he, along with his manager, Mr. Sharma, abused the Petitioner using filthy language and even assaulted her when she tried to speak with him. Due to these assaults, she sustained injuries and, further, during the said incident, the accused threatened the Petitioner with dire consequences to her life and limb, if she failed to abort the child. Further, the accused threatened that her unborn child, her son, and she would face severe consequences to their lives and limbs, as he had extreme influence both financially and politically, and that he could easily do away with her.

15. It is most humbly submitted that, shocked by the accused’s abusive and criminal behaviour, the Petitioner was left in the lurch, and it was at this juncture that she came to know that he had never actually divorced his first wife and that all this time he had been lying to her about his past issues, which he claimed to have had with his first wife. Further, the Petitioner understood that all the while, the accused Madhampatty Rangaraj had been falsely claiming that he was separated from his first wife to have coitus with the Petitioner by deceitful means.
16. It is most humbly submitted that the Petitioner was shocked to find out that the accused had cheated her and cohabited with her by deceitfully inducing a belief of lawful marriage and entered into a physical relationship under the fraudulent claim of being judicially separated from his first wife, and further, using fraudulent means, he deceived the Petitioner and persuaded her to divorce her first husband.

17. It is most humbly submitted that the Petitioner was emotionally shattered upon learning that the accused had married her by giving false hope that he was judicially separated from his first wife; therefore, unable to understand the whole situation, the Petitioner went to meet the accused Madhampatty Rangaraj on 13-08-2025 as she came to know that he was staying at Meridian Hotel. However, when the Petitioner tried to meet him, he refused and instead said he would meet her on 19-08-2025, but again, there was no reply from him. Therefore, the Petitioner went to his shooting location on 20-08-2025 along with her mother and sister to meet him. However, there was no response from him, so the Petitioner waited overnight at the “Feathers Hotel” where he was staying, and at about 3:15 a.m., the accused met the Petitioner. She requested him to take care of her and her unborn child and confronted him about the false promises made by him, for which he abused the Petitioner and brutally assaulted her, inflicting injuries.

18. It is most humbly submitted that, shocked by the criminal conduct and behaviour of the accused, and unable to tolerate the same, the Petitioner lodged a police complaint with the Commissioner of Police to obtain justice on 29-08-2025, seeking appropriate action against the said Madhampatty Rangaraj for the illegalities committed by him.

19. It is most humbly submitted that, subsequent to the Petitioner’s complaint, the accused, with an ulterior motive to safeguard himself from criminal prosecution and with the ill-intention of giving a commercial colour to the criminal case, filed a civil suit in C.S. No.231 of 2025 before this Hon’ble Court, through his company, Madhampatty Thangavelu Hospitality Pvt. Ltd., represented by its authorized representative, on the averment that the Petitioner had disparaged and defamed the said private limited company. Further, the accused himself also instituted another civil suit in C.S. No.250 of 2025 before this Hon’ble Court with applications for interim relief on the pleadings that the Petitioner had infringed his personality rights and had commercially exploited his celebrity status and caused loss to his publicity and consequent commercial gains by defaming him. The above civil suits are still pending before this Hon’ble Court.

20. It is humbly submitted that the Petitioner is a victim of the illegalities committed by the accused, namely Madhampatty Rangaraj. It is necessary to note that initially, the Petitioner lodged a complaint before the 1st Respondent, i.e., Commissioner of Police, on 29-082025. The said complaint was filed in person by the
Petitioner, but despite lodging the complaint on 2908-2025, no action was taken by the 1st Respondent. Therefore, the Petitioner addressed a follow-up representation dated 10-09-2025, seeking appropriate action against the accused Madhampatty Rangaraj for his illegal activities. Even after addressing that representation on 10-09-2025, no action was initiated by the 1st Respondent. Therefore, a separate complaint dated 11-09-2025 was lodged before the jurisdictional police, stating all the incidents and illegalities committed by the accused Madhampatty Rangaraj. Subsequently, it was informed to the Petitioner by the police authorities that the complaint had to be filed before the Thiruvanmiyur Police Station, as the residence of the Petitioner comes under the jurisdiction of Thiruvanmiyur. Therefore, another complaint was addressed to the Deputy
Commissioner of Police, Adyar Police Station, and Inspector of Police, Thiruvanmiyur Police Station, for appropriate action against the accused
Madhampatty Rangaraj.

21. It is pertinent to note that the Petitioner was made to run from pillar to post for registration of a crime against an accused who has cheated her and forced her into multiple abortions. The complaint lodged by the Petitioner was kept in cold storage without any action. Therefore, with no other alternative, the Petitioner exercised her available remedies and also made a representation to the Tamil Nadu State Commission for Women on 08-10-2025 seeking necessary action. It was only in those circumstances, a crime was registered by the 2nd Respondent against the accused Madhampatty Rangaraj in FIR No.179 of 2025, dated 08-10-2025, for offences under Section 115 (2) and 351 (2) of B.N.S.2023.

22. It is most humbly submitted that the Petitioner was shocked by the fact that despite her complaint making out a case for cognizable offences, the 2nd Respondent police had only registered two offences, which are of a non-cognizable and bailable nature. It is pertinent to note that the complaint of the Petitioner makes a clear case for several cognizable offences; however, the 2nd Respondent has chosen only to register two minor, non-cognizable and bailable offences. The Petitioner had clearly stated in her complaint the illegalities committed by the accused, which are in the nature of cheating, criminal intimidation with threat to cause death and grievous hurt, cruelty by husband, causing of miscarriage, causing of miscarriage without the woman’s consent, destruction of electronic records to prevent their production in judicial proceedings, illegal cohabitation under the pretext of lawful marriage and offences under the provisions of the Information
Technology Act, 2000 and other acts. Further, the Petitioner also had categorically mentioned the fraudulent intention of the accused, who deceitfully induced the Petitioner into a marital relationship and had coitus with her. The said act of the accused stated in the complaint clearly attracts the offence under Section 81 of B.N.S.2023, as the complaint of the Petitioner clearly makes out a case for cohabitation caused by a man deceitfully inducing a belief of lawful marriage. The Petitioner in her complaint has categorically stated the criminal behaviour of the accused and the forceful abortions committed by him and the fact that he had falsely claimed that he was judicially separated from his first wife, namely Mrs. Shruthi, for the sole reason of having coitus with the Petitioner by deceitful means.

23. It is most humbly submitted that subsequent to the registration of the FIR by the 2nd Respondent, the Petitioner addressed a detailed representation dated 10-10-2025 to the Commissioner of Police, Deputy Commissioner of Police, CCB, along with other authorities to include the necessary offences made out in the Petitioner’s complaint. In that representation, the Petitioner particularly stated the specific instances of crime committed by the accused and the necessary penal offences they would attract. However, even after a detailed representation, the 2nd Respondent did not act upon the representation and did not alter the provisions included in the FIR nor proceed with the investigation.

24. It is humbly submitted that, from the outset, the investigation by the police officials was not satisfactory for various reasons, as the complaint was lodged with the 1st Respondent on 29-08-2025, and even after the complaint made out a case for cognizable offence, no action was taken for nearly 1½ months. Even after continuous follow-up from the Petitioner, there was complete inaction by the
Respondent police in registering the FIR, and only after a representation was made to the Tamil Nadu State Commission for Women did the 2nd Respondent register an FIR for minor offences, contrary to what had been stated in the Petitioner’s complaint. This significant delay by the Respondent police clearly raises concerns about the investigation process and the fairness of any investigation carried out by the 2nd Respondent police.

25. It is most humbly submitted that the investigation conducted by the 2nd Respondent police is in a lackadaisical manner, without any determination, and from the very first preliminary investigation, they have acted with a predetermined notion and have been premeditated and conclusive in their approach. The 2nd Respondent, after the complaint was forwarded to them, adopted a preconceived notion that it was a case of a relationship between two adults gone sour, whereas the Petitioner’s case is not about a relationship which turned bitter, but about the illegality committed by the accused. The accused had cheated the Petitioner by deceitfully inducing her to believe in a lawful marriage and cohabited with her under that deceitful belief; when she became pregnant, he forced her to abort twice, causing detrimental effects to her health, and when she opposed the third abortion insisted on by the accused, he assaulted her on various occasions, causing permanent disability. When the Petitioner confronted him about the illegality, the accused threatened her with dire consequences to her life and limb.

26. It is most humbly submitted that the clear case of offences set out in the Petitioner’s complaint has been completely ignored by the 2nd Respondent police, and even the other accused named in the complaint – viz. Arun Babu and the accused Madhampatty Rangaraj’s manager, Mr. Sharma were not arrayed as accused in the FIR, even though specific statements and overt acts were made against them regarding the illegalities they committed.

27. It is most humbly submitted that the enormous delay in registration of the FIR, coupled with the high stature of the accused in society, raises a clear question about the credibility of the investigation conducted by the 2nd Respondent. It would not be out of context to mention that, the accused Madhampatty Rangaraj is a person of high stature in society and is a celebrity who has been in contact with several highly influential individuals. The accused has been one of the celebrated chefs, and it is beyond dispute that he catered to the marriage functions of several highprofile politicians, celebrities, senior officials, and other influential persons in the State. It is important to
note that the Tamil Nadu State Commission for Women has also observed the popularity enjoyed by the accused in society and has recognized that an independent investigation is necessary to achieve the interests of justice.

28. It is most humbly submitted that the investigation conducted by the respondent police, even from the preliminary instance of the complaint is biased and filled with premeditated conclusions. The petitioner had lodged her complaint initially before the 1st respondent on 29-08-2025, despite the fact that the complaint was lying with the 1st respondent for nearly 30 days, there was no action against the accused even after the petitioner’s complaint made a case for cognizable offence. The petitioner was put in dark about the status of the complaint and therefore, she had addressed follow up reminders to the first respondent and also made separate complaints to the jurisdictional police, thereafter, the jurisdictional police with ulterior motive did not take up the investigation on the pretext of jurisdiction issues and made the petitioner run from pillar to post for taking cognizance in her advanced stage of pregnancy causing her severe physical exhaustion.

29. While so, despite the stern efforts of the petitioner, the respondent police were not probing the complaint and only after continuous follow up of the petitioner, the deputy commissioner of police thousand lights called the petitioner for investigation. The petitioner abided the call and appeared before the thousand lights special wing for investigation, where the petitioner was made to wait for several hours in the name of investigation from 10:45 am to 5:45 pm without any basic requirements, that too in her advanced stage of pregnancy. The petitioner underwent much turmoil and exhaustion on the hope that justice would be served to her. However, on contra, the petitioner came to tacit that the accused was called for enquiry after two days and was provided with differential treatment subduing the inquiry.

30. Furthermore, all the materials produced by the petitioner, which are documentary in nature had been omitted to be considered by the police officials and when the petitioner approached the Tamil Nadu State Women commission on 08-10-2025 at about 11.00 A.M. and when the commission called the police official for inquiry, the 2nd Respondent police in a hasty manner registered the present FIR contrary to the contents of
the complaint and has caused much injustice to the petitioner.

31. The Petitioner most humbly submit that, she is a woman in the advanced stage of pregnancy and the continuing inaction of the second respondent police would amount to violation of fair justice. It is requisite to note that subsequent to the receipt of the FIR on 09-10-2025, the petitioner went to the Commissioner office to follow up the complaint on 10th October, as the petitioner was instructed to follow up the complaint when the FIR was served on her. As instructed in the office of the 1st Respondent, the petitioner went to meet the Deputy Commissioner Police, Thousand Lights, even there the petitioner was made to wait for more than 2 hours and she was sent back without any update on the complaint, since then, there is a total inaction on the complaint and during all these process the petitioner was ill-treated and insulted and was made to wait for several hours thereby violating her dignity and fundamental rights enshrined under Article 21 of the constitution. It is pertinent to note that these lacunas and dilatory practice intended to prolong the investigation coupled with the fact that the petitioner was illtreated on several instances by the police would make the present case a special and peculiar case for transfer of the investigation to an independent agency.

32. It is most humbly submitted that, although the complaint of the Petitioner was lodged on 29-08-2025, there was no action till October 2025. The 2nd Respondent police merely prolonged the issue in the name of investigation and, on a few occasions, called for investigation, but all was in vain, as no specific action was taken against the accused. Moreover, to the Petitioner’s shock and surprise, the 2nd Respondent police registered a crime only for minor offences, though her complaint made out a clear case for the following cognizable offences: –

(a) The fraudulent intention of the accused Madhampatty Rangaraj to induce the Petitioner by deceitful means into marriage by falsely claiming to be judicially separated from his 1st wife and thereby, on such false pretext, had coitus with the Petitioner, which is punishable under
Section 318 of B.N.S.2023;

(b) The fraudulent and criminal act of the accused Madhampatty Rangaraj forcing the Petitioner into abortions twice when the Petitioner became pregnant, causing miscarriage by forceful means, punishable under Sections 88 and 89 of B.N.S.2023;

(c) The illegal act of the accused Madhampatty Rangaraj continuously assaulting the Petitioner and causing physical and mental cruelty during the relationship, punishable under Sections 85, 86,
116, and 117(2) of B.N.S.2023;

(d) The illegality committed by the accused, where Madhampatty Rangaraj induced a deceitful belief of lawful marriage, as if he got divorced from his 1st wife, and had coitus/cohabitation with the
Petitioner, punishable under Section 81 of
B.N.S.2023;

(e) The act of the accused in destroying electronic evidence which was in the Petitioner’s possession to establish her relationship, punishable under Section 241 of B.N.S.2023 and Sections 65 and 66 of the I.T. Act, 2000;

(f) The illegal act of the accused issuing continuous death threats to the Petitioner, endangering her life and limb along with her children’s lives, punishable under Section 351(3) of B.N.S.2023, and
the continuous harassment, causing physical and mental assault on the Petitioner, punishable under Section 4 of the Tamil Nadu Prohibition of
Harassment of Women Act, 1998;

33. Therefore, from the list of offences stated above, it is categorically clear that the 2nd Respondent police, with an ulterior motive, for reasons best known to them, omitted to include these offences, favouring the accused, even though the complaint of the Petitioner made out a case for those offences. This lapse in investigation by the 2nd Respondent police is against the basic principles of investigation and violates the fundamental rights of the Petitioner. Moreover, this defective investigation will ultimately lead to an abuse of the process of law.

34. It is most humbly submitted that even the Tamil Nadu State Commission for Women has taken cognizance of this defective investigation conducted by the 2nd Respondent police and, in its recommendation vide Roc.No.5118/WC/A1/2025, has pointed out that the offences included in the FIR are insufficient and that several necessary offences have not been taken cognizance of in the complaint.

35. It is requisite to note that, the act of the 2nd respondent police omitting to include the offences which are necessary to be included, delaying the process of investigation, not arraying the necessary accused in the FIR and the in-action on the part of the 2nd respondent in the investigation process, which is clearly revealed from the fact that the accused is not secured for investigation, would clearly make the present case a fit case for transfer to an independent investigation agency to achieve the interest of justice.

36. It is most humbly submitted that the judicial precedents pertaining to transfer of investigation from one agency to another have been streamlined by the Hon’ble Supreme Court in various decisions. The
Hon’ble Apex Court, in the case of “State of West Bengal and others –Vs– Committee for Protection of Democratic Rights, West Bengal and others (2010 3 SCC 571),” has categorically upheld the powers of the Hon’ble High Court to transfer the investigation of a criminal case to an independent investigation agency and has also observed that, although there cannot be any fixed guidelines for transfer of investigation, such transfers must be ordered in exceptional circumstances where necessary for doing complete justice and enforcing fundamental rights. The aforesaid decision of the Hon’ble Supreme Court squarely applies to the present case, as the Petitioner’s fundamental rights under Article 21 are violated by the 2nd Respondent, as even after a clear case for a cognizable offence is made out, the 2nd Respondent has only registered minor, noncognizable, and bailable offences and, moreover, even after registering a crime after a delay of 1½ months, the accused has not been secured or arrested and many other individuals who committed illegalities against the Petitioner in connivance with the main accused were not arrayed as accused in the present crime.

37. It is most humbly submitted that the law is well settled regarding the power of transferring investigation to another agency, which is to be exercised by the Hon’ble Court when there is a requirement to do complete justice between the parties and to instill confidence in the public or in situations where the investigation by the State Police lacks credibility. Such legal precedent has been laid out in the judgment of the Hon’ble Apex Court in “K.V. Rajendran –Vs– Superintendent of Police, CBCID, South Zone (2013 12 SCC 480).” The aforesaid principles clearly suit the present case, as the accused is an individual of high influence and it is beyond dispute that the individual has been celebrated in the field of catering and has served many high-profile politicians, senior officials, and influential persons in the State. In view of these circumstances, coupled with the facts that the investigation has been delayed, necessary offences to be included were not included, necessary individuals were not arrayed as accused in the FIR, and despite delay, no proper investigation has been initiated, and moreover, the accused has not been secured for investigation, considering his reputation and influence in society, there are all possibilities of detriment to the process of investigation leading to injustice. Therefore, the present case is one of those specific cases where there are exceptional circumstances for transfer of investigation.

38. It is most humbly submitted that the Petitioner has been cheated by the accused and now has been left in the lurch without any remedy or support in her advanced stage of pregnancy. Despite these tough circumstances, the Petitioner has made her fullest effort to bring the accused before the Hon’ble Court of Law for the criminal activities committed by him. However, the lackadaisical attitude and defective investigation conducted by the 2nd Respondent, as it is clear from the delay in FIR registration, the manner of its registration and the biased treatment towards the petitioner clearly demonstrate the necessity for transfer of the investigation to an independent agency. Therefore, with no other alternative remedy available, the Petitioner has approached this Hon’ble Court, seeking exercise of its inherent powers to meet the ends of justice and secure justice. Hence this petition.

39. It is humbly submitted that a prima facie case and the balance of convenience are in favour of the Petitioner for transfer of the present FIR from the 2nd Respondent to the 3rd Respondent or any other independent agency for a fair investigation.

40. The Petitioner craves leave of this Hon’ble Court to seek the liberty of raising any other grounds at the time of hearing.

For the reasons stated above, it is most humbly and respectfully prayed that this Hon’ble Court may be pleased to transfer the investigation in Crime No.179 of 2025, dated 08-10-2025, on the file of the 2nd Respondent to the 3rd Respondent, i.e., Additional Director General of Police, CBCID, Chennai, or any other independent agency and pass such other order or orders as this Hon’ble Court may deem fit and proper in the interest of justice and thus render justice.

Dated at Chennai on this the day of October,2025.

COUNSEL FOR THE PETITIONER

MEMORANDUM OF CRIMINAL ORIGINAL PETITION
FILED UNDER SECTION 528 OF
BHARATIYA NAGARIK SURAKSHA
SANHITA,2023
IN THE HIGH COURT OF JUDICATURE
AT MADRAS

CRL.O.P.No. OF 2025 in
Crime No. 179 of 2025
(On the file of Assistant Commissioner of Police, CCB-I, Chennai-CCB)

Joy (F/A. 37 Yrs)
W/o. Madhampatty Rangaraj,

… Petitioner/Defacto
Complainant

V/s

Commissioner of Police, Greater Chennai Police, & 2 others.
…. Respondents

TRANSFER PETITION FILED UNDER SECTION 528 OF B.N.S.S, 2023.

M/s. R.SUDHA (449/2000),
R.V.DINESH KUMAR (350/2000),
M.MATHAN RAJ (2070/2018),
S.SARAVANAN (3130/2024)
A.P.SACHITHANANTHAM (3734/2024)
COUNSEL FOR PETITIONER
CELL No.