TULA RAM & ORS. vs KISHORE SINGH

The Supreme Court clarified that a Magistrate can order an investigation under Section 156(3) of the Criminal Procedure Code (CrPC) only before taking cognizance under Sections 190, 200, and 204. Once cognizance is taken, the Magistrate must follow the procedures outlined in Section 200 and can either issue process or direct an inquiry. The Court emphasized that Sections 190 and 156(3) are mutually exclusive, and a Magistrate cannot compel the police to submit a charge-sheet after an investigation ordered under Section 156(3). The judgment upheld the procedural integrity of the CrPC in handling complaints and investigations.