Court Upholds Earlier Order, Says Complaint Lacked Supporting Evidence and Proper Legal Procedure

Bhubaneswar, September 2: In a significant legal development in Odisha, the Khordha District and Sessions Court has dismissed a criminal revision petition concerning allegations of misuse of government-funded helicopter services by former Chief Minister Naveen Patnaik and former bureaucrat V.K. Pandian.

The court, presided over by Khordha Sessions Judge Biranchi Narayan Mohanty, rejected the revision petition after finding that the complainant had failed to establish a prima facie offence against the two prominent former members of the previous state administration. The court also observed that mandatory legal procedures had not been followed while filing the complaint.

The matter originated from a private complaint filed by Sudhir Charan Mohanty. The complaint alleged that helicopters had been used for tours involving Patnaik and Pandian, with the expenditure being met from the state government treasury. The complainant had alleged that the cost of such helicopter use amounted to a substantial sum and questioned the authorization and circumstances under which the services were provided.

After the police did not register an FIR on the complaint, the petitioner approached the Sub-Divisional Judicial Magistrate (SDJM) court in Bhubaneswar. Following consideration of the matter and a police report, the SDJM court dismissed the complaint on March 25, 2026, holding that it did not make out a cognisable case.

The complainant subsequently challenged that decision before the Khordha District and Sessions Court through a criminal revision petition. The case attracted considerable political and public attention because of the involvement of the former Chief Minister and Pandian, who played a prominent role in the previous BJD government.

During the proceedings, the court examined whether the allegations were supported by adequate material and whether the complainant had complied with the requirements under the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023.

The court concluded that the petitioner had not produced sufficient supporting material to substantiate the allegations. It also held that mandatory procedural requirements under Section 173(4) of the BNSS had not been complied with. In addition, the court questioned the complainant's locus standi under the relevant provisions of the law.

The court therefore found no illegality in the earlier SDJM order dismissing the complaint and rejected Criminal Revision No. 171 of 2026 as lacking merit.

The allegations had earlier generated political debate, particularly over the reported expenditure on helicopter and chartered aviation services during the previous government. A July report had stated that the court was seeking records concerning helicopter operations and related expenditure, including payments made to aviation service providers.

However, the latest order has now upheld the dismissal of the private complaint at the district court level. The court's decision does not amount to a finding that every allegation surrounding government aviation expenditure is factually resolved; rather, it establishes that the particular complaint and revision petition did not meet the necessary evidentiary and procedural requirements.

The dismissal provides legal relief to Naveen Patnaik and V.K. Pandian in this particular proceeding and brings the private complaint to a close at the district court level, unless any further legal remedy is pursued.

The development is expected to attract attention in Odisha's political circles, as allegations concerning the use of public funds and administrative decisions during the previous government have remained subjects of political discussion.

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