Wild Life (Protection) Act, 1972 — Ss. 50(1), 50(8), 50(9), 55 — Investigation — Whether only Forest/Wildlife Officers may investigate — Held: No. Police (including CBI, if properly authorised) may investigate offences under the Act.

A. Wild Life (Protection) Act, 1972 — Ss. 50(1), 50(8), 50(9), 55 — Investigation — Whether only Forest/Wildlife Officers may investigate — Held: No. Police (including CBI, if properly authorised) may investigate offences under the Act.

1. Section 50(1) contains a non obstante clause authorising not only the Director/Authorised Forest Officer/Wildlife Warden but also a Police Officer not below the rank of Sub-Inspector to inspect, search, seize and arrest for offences under the Act.
   Held: Police officers are not excluded from investigating WLPA offences.
   (Para …)

2. Section 50(8) empowers only officers not below the rank of Assistant Director, Wildlife Preservation or Wildlife Warden to issue search warrants, enforce attendance of witnesses, compel production of documents and receive and record evidence.
   Held: This is a special evidentiary power distinct from general investigation; the existence of this special power does not exclude police investigation under CrPC.
   (Para …)

3. Section 55 prescribes that cognizance shall be taken only on a complaint by the designated authorities.
   Held: This affects cognizance, not the power of police/CBI to investigate.
   (Para …)

B. Delhi Special Police Establishment Act, 1946 — Ss. 3, 5, 6 — CBI investigation into WLPA offences — Validity of Central notification — Consent of State — Held: CBI can investigate provided notifications under Ss. 3, 5 and consent under S. 6 are issued.

4. Central Government had issued a notification under S.3 specifying WLPA offences as offences that may be investigated by the Delhi Special Police Establishment (CBI).
   State of U.P. granted consent under S.6, and the Central Government issued formal extension order under S.5.
   Held: CBI had full jurisdiction to investigate the WLPA offences in the case.
   (Para …)

5. Contention that WLPA is a “self-contained code” excluding CrPC and CBI rejected.
   Held: WLPA contains special provisions only for search, seizure, arrest, recording of evidence, complaint procedure, and compounding, but does not exclude CrPC investigation.
   (Para …)

C. Criminal Procedure Code, 1973 — S.4(2) — Offences under special laws — Extent of applicability of CrPC — WLPA does not displace police investigative powers.

6. S.4(2) CrPC provides that offences under special laws shall be dealt with “according to CrPC unless the special law contains a contrary provision.”
   Held: WLPA contains no express exclusion of police investigation; therefore, CrPC investigation provisions apply fully.
   (Para …)

D. Distinction — FERA cases (CBI v. State of Rajasthan, 1996 9 SCC 735) not applicable.

7. FERA contains a complete mechanism vesting investigation exclusively in Enforcement Directorate; there was no notification authorising CBI under FERA.
   Held: WLPA fundamentally different — it expressly includes police officers under S.50(1). Hence the earlier FERA judgment does not apply.
   (Para …)

E. Result

8. Notifications having been properly issued under DSPE Act, CBI was competent to investigate WLPA offences and to file complaint under S.55 WLPA (vide Central Government notification dated 7-4-2000).
   Appeal dismissed.