Bhubaneswar: The Sessions Court, Khurda at Bhubaneswar has dismissed a criminal revision petition filed against former Chief Minister Naveen Patnaik and former bureaucrat V K Pandian.
Advocate and social worker Sudhir Charan Mohanty had filed the revision challenging the SDJM, Bhubaneswar’s order dated March 25, 2026 which had dismissed his complaint against Patnaik and Pandian.
The complaint had alleged misappropriation and misuse of public funds exceeding Rs 500 crore besides allegations concerning helicopter travel and expenditure linked to public meetings. The petitioner had relied upon information claimed to be collected through RTI.
The Sessions Court upheld the SDJM’s decision highlighting three key issues:
Section 173(4) BNSS: The Court held that the mandatory statutory procedure following alleged refusal to register FIR was not complied with. The report submitted to DCP was found to be cryptic and was not sent by post as required.
No prima facie material: The Court noted that the petitioner had not produced documentary material or RTI information allegedly collected by his witnesses to establish a cognizable offence or alleged involvement of respondents. The allegations were found to be omnibus and unsupported by substantive material.
Locus under Section 33 BNSS: The Court further held that offences alleged in the complaint did not fall within categories specified under Section 33 BNSS and consequently petitioner did not have requisite locus to present complaint under that provision.
The Sessions Court found no illegality in the SDJM’s March 25, 2026 order and dismissed Criminal Revision.








