STATE OF BIHAR vs MURAD ALI KHAN, FARUKH SALAUDDIN & VIKRAMSINGH

The Supreme Court held that under Section 51 of the Wild Life Protection Act, 1972, cognizance of an offence can only be taken by a Magistrate on the complaint of the designated officer as per Section 55. The Court restored the Magistrate's order to take cognizance despite an ongoing police investigation, clarifying that Section 210(1) of the Code of Criminal Procedure, 1973 does not apply in this context. The High Court's quashing of the proceedings was set aside, allowing the criminal case to proceed as per law.