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Giriraj Sharma vs. State of Rajasthan & Anr.

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General (Criminal) Rules, 1980–Deleterious remarks against the petitioner-Investigation Officer–Three vital factors which ought to be considered prior to making any disparaging remark-
(i) Whether the party whose conduct is in question, is before the Court and is tendered with a reasonable opportunity to explain himself,
(ii) Whether sufficient evidence is placed on record to justify the said remarks,
(iii) Whether it is necessary for the decision of the case as an integral part thereof, to animadvert on that conduct.
Order passed by the Trial Court is strictly in accordance with the settled principles of law–Trial Court passed the speaking order, meticulously noting the rationale qua passing the said remarks and initiating the inquiry against the petitioner–Interference declined.