Justice Wani has held that this was substantial compliance of Sections 154 (1) and 154 (3), CrPC when the complainant forwarded the details of the complaint via WhatsApp and email to the police officials concerned.
As such, the Court held that the complainant has seemingly complied with the requirements to approach the magistrate with an application under Section 156, CrPC.
“Even if it is assumed that the Whatsapp chats and the email aforesaid were not part of the complaint at the time of its filing before the Magistrate as at this stage while examining the validity of the complaint as also the impugned order, non-filing of the same before the Magistrate would be having no effect on the merits of the application now in view of the said material being available before this court,” the Court added.
Source: Barandbench
