The Orissa High Court has recently ordered the State's Director General of Police (DGP) to handover the investigation to an officer not below the rank of Deputy Superintendent of Police (DSP) or Sub-Divisional Police Officer (SDPO) in an alleged case of public stripping of a Muslim man and coercing him to utter 'Jay Sri Ram'.

Allowing the petition filed by the father of the victim, the Bench of Justice Savitri Ratho held–

“The investigation in the case is in progress, but keeping in view the nature of the allegations and as it is not disputed that the incident had been videographed and made viral over social media, in the opinion of the Court that it would be proper if the investigation of the case is supervised by a Senior Officer not below the rank of DSP.”

In the first week of January 2026, the son of the petitioner (hereinafter the 'victim') was allegedly assaulted by the accused persons, who also removed his wearing apparels and purportedly dragged him on the ground. Later, they tied his hands and legs with rope and while he was still naked, they allegedly mocked him on a public road. Notwithstanding his religious affiliation, the story goes that the assailants forced him to utter 'Jay Sri Ram'.

A complaint was submitted to the Inspector-in-Charge of Bahalda Police Station, in the district of Mayurbhanj on 03.01.2026, along with the video recording of the incident. The police registered the FIR under Sections 126(2) [wrongful restraint], 296 [obscene act], 155(2), 117(2) [voluntarily causing grievous hurt], 133 [assault or criminal force to dishonour person], 351(3) [criminal intimidation], 3(5) [common intention] of the Bharatiya Nyaya Sanhita (BNS) only on 04.01.2026, after the video went viral.

The petitioner filed this case before the High Court seeking to transfer the investigation of the case to the Crime Branch or to a Special Investigation Team (SIT). The State prima facie opposed the prayer on the ground that the petitioner is neither the victim nor the informant and therefore, lacks locus standi to the maintain the petition. Further, no officer of the Crime Branch was arrayed as opposite party.

Keeping aside the aforesaid, Justice Ratho expressed inclination to grant indulgence in the case keeping in view the severity of the allegations, which are duly supplemented by video recordings. Thus, the Judge deemed it apposite to order investigation under the supervision of a senior and seasoned police officer.

“In view of the background of the case, the opposite party no.3 is directed to assign a Senior Officer not below the rank of the post of DSP / SDPO to supervise the investigation of the case who shall insure that investigation is conducted in a fair manner and after completion of investigation, final form is submitted in accordance with law,” she ordered.

Case Title: Sk. Hanif v. State of Odisha & Ors.

Case No: CRLMP No. 283 of 2026

Date of Order: March 16, 2026

Counsel for the Petitioner: Mr. P.R. Chhatoi, Advocate

Counsel for the Opposite Parties: Mr. Sarathi Jyoti Mohanty, Additional Standing Counsel

Citation: 2026 LiveLaw (Ori) 36

Click Here To Read/Download Order