Daijiworld Media Network - Bhubaneswar

Bhubaneswar, Sep 2: The Sessions Court of Khurda, Bhubaneswar, on Wednesday dismissed a criminal revision petition filed against former Odisha Chief Minister and Leader of Opposition Naveen Patnaik and his close aide and former bureaucrat VK Pandian over alleged misappropriation or misuse of public funds.

Advocate and social worker Sudhir Charan Mohanty of Bhubaneswar had filed the revision petition challenging an order of the SDJM, Bhubaneswar, dated March 25, 2026, which had dismissed his complaint against Patnaik and Pandian.

Mohanty said he had lodged an FIR on August 14, 2024, at the Capital Police Station in Bhubaneswar. In his complaint, he alleged that Pandian and Patnaik had travelled across all districts of Odisha and undertaken several helicopter trips without government sanction or payment from the state exchequer.

Citing information obtained through the Right to Information (RTI), Mohanty further alleged that the expenses were borne by mining owners, land mafias, real estate operators, non-Odia contractors and other sources of unaccounted money.

The petitioner also claimed that the Inspector-in-Charge of the Capital Police Station did not register the FIR until August 19, 2024.

He subsequently submitted the written FIR to the Deputy Commissioner of Police, Bhubaneswar, where it was received, but alleged that no FIR was registered against Pandian and Patnaik despite its receipt at the DCP’s office.

Mohanty thereafter filed a 1 CC case under various sections of the Indian Penal Code (IPC). The case was later dismissed by the SDJM Court, Bhubaneswar.

Following the dismissal, he approached the Sessions Court challenging the SDJM Court’s order.

The Sessions Court, however, found no illegality in the order passed by the SDJM Court on March 25, 2026.

Sessions Judge, Khurda, Biranchi Narayan Mohanty, observed that the complainant had neither established a case under the penal provisions cited in his complaint with supporting material nor complied with the mandatory requirements under Section 173(4) of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, before filing the complaint.

The court also held that the petitioner lacked the required locus standi to present the complaint under Section 33 of the BNSS, 2023.

“Thus, in view of the aforesaid discussion, this Court is of the considered opinion that the complaint/petitioner neither made out any case under any of the penal sections referred to in the complaint petition with supported materials nor adhered to the mandatory compliance of Section 173(4) of BNSS, 2023 before presenting the complaint nor he had got any locus-standi to present the complaint in terms of Section 33 of BNSS, 2023,” the judge observed.