The Supreme Court set aside a trial court order summoning former Prime Minister Manmohan Singh in a coal block allocation case. The Court held that the trial court had no justification to take cognizance while ignoring CBI's closure report filed in the matter. The ruling reaffirms the principle that magistrates cannot mechanically issue summons overriding a closure report without cogent reasons, protecting accused persons from arbitrary prosecution initiation at the trial court stage.

This case sits at the intersection of criminal procedure, magisterial powers, and the CBI's prosecutorial discretion. Under the CrPC (now largely mirrored in BNSS 2023), when an investigating agency files a closure report—also called a final report under Section 173—the magistrate has three options: accept it, reject it and direct further investigation, or take cognizance against the accused despite the closure. However, the Supreme Court has consistently held that this third option is not a free pass. A magistrate must apply judicial mind and record reasons for disagreeing with the investigating agency's conclusion. Simply ignoring a closure report and issuing summons is procedurally improper. The Manmohan Singh ruling reinforces this safeguard, particularly in politically sensitive cases where courts must guard against being instruments of harassment. The coal block allocation scam, investigated by the CBI, implicated several high-profile individuals. CBI's decision to file a closure report against Dr. Singh represented the agency's considered view of insufficient evidence. The trial court's act of summoning him despite this report—without assigning reasons for rejecting the closure—was held unsustainable. For CLAT PG, this case tests understanding of Section 173 CrPC, the magistrate's power under Section 190, and the precedent-backed principle that cognizance taken contrary to a closure report must be judicially justified, not reflexive.