RANDHIR SINGH RANA vs THE STATE BEING THE DELHI ADMINISTRATION.

The Supreme Court addressed the issue of whether a Judicial Magistrate can order further investigation after taking cognizance of an offence based on a police report. The Court clarified that while a Magistrate has the power to order investigation under Section 156(3) of the Code of Criminal Procedure, 1973 only before cognizance is taken, once cognizance is taken, the Magistrate cannot order further investigation as it encroaches on police authority. The Court upheld the principle established in Tula Ram v. Kishore Singh, 1977 (4) SCC 459, confirming that the Magistrate's powers are limited post-cognizance.