Nawal Kishore Meena v. State of Rajasthan; 2026 INSC 71 - S.17 Prevention Of Corruption Act - Investigation By State Agencies
Prevention of Corruption Act, 1988: Sections 17 - Section 17 does not exclude or prevents the State Police or a Special Agency of the State from registering a crime or investigating cases relating to bribery, corruption and misconduct against Central Government employes- The Vigilance and Anti-Corruption Bureau (VACB) is also a wing of State Police- The offences under the PC Act are also cognizable and can, therefore, be investigated by the State Police or VACB - The only rider is that the investigation can be done only by a police officer of the rank specified in Section 17 of the PC Act. (Para 8)
Criminal Investigation - The relation between the CBI and the State Police is supplementary to each other and as per the CBI constitution and inter se arrangement between CBI and State police there are several areas where the CBI and the Police require inter se cooperation and support. (Para 5)
Code of Criminal Procedure 1973 - Section 156 -The existence of a special law by itself cannot be taken to exclude the operation of Cr.P.C. Unless the special law expressly or impliedly provides a separate provision for investigation, the general provision under Section 156 of Cr.P.C shall prevail. (Para 6)
Code of Criminal Procedure 1973 - Section 2(s)- The Vigilance and Anti-Corruption Bureau (VACB) is also a wing of State Police. (Para 8)
Case Info
Case Details
- Case name: Nawal Kishore Meena @ N.K. Meena v. State of Rajasthan
- Neutral citation: 2026 INSC 71
- Coram: Hon’ble Mr. Justice J.B. Pardiwala; Hon’ble Mr. Justice Satish Chandra Sharma
- Judgment date: 19-01-2026
Caselaws and Citations
- A.C. Sharma v. Delhi Administration, (1973) 1 SCC 726.
- Ashok Kumar Kirtiwar v. State of Madhya Pradesh, 2001 SCC OnLine MP 83.
- Arvind Jain v. State of Madhya Pradesh, 2017 SCC OnLine MP 1294.
- G.S.R. Somayaji (Dr.) v. State through CBI, 2001 SCC OnLine AP 1196.
- The State of Kerala v. Navaneeth Krishnan, 2023 SCC OnLine Ker 5730.
Statutes/Laws Referred
- Prevention of Corruption Act, 1988: Sections 17, 22, 13(1)(e).
- Code of Criminal Procedure, 1973: Sections 4(1), 4(2), 156(1), 156(2), 2(s), Chapter XII, Chapter XIII.
- Delhi Special Police Establishment Act, 1946: Section 3; discussion of consent and CBI constitution/resolution (01.04.1963).
#SupremeCourt holds that State Police or its Special Agency can register a crime or investigate cases relating to bribery, corruption and misconduct against Central Government employees ! https://t.co/ZYVVxO0WaS pic.twitter.com/46ZZ2XdOLC
— CiteCase 🇮🇳 (@CiteCase) January 20, 2026