Report of the Joint Parliamentary Committee, (hereinafter referred to as “JPC”), is the Report of the Parliament. That, JPC consisted of the members of both Houses of Parliament. That, the entire object of the Report was to keep the Parliament informed of the events which took place and the circumstances under which the scam took place. The Report is a public document as defined u/s 74(1)(iii) of the Evidence Act.
Parliament is required to probe into certain state of affairs of public concern before enacting a law. For this purpose, the Legislature has the power to probe into such state of affairs. For that purpose it can constitute a Committee. JPC is one such Committee. When the members of the JPC, who are also members of the Parliament, entered into a legislative enquiry, then such an enquiry is an integral part of the legislative work of the Parliament.
In Pathan Mohammed Suleman Rehmatkhan Vs. State of Gujarat and Others, , the Supreme Court was concerned with the dismissal by the Gujarat High Court of a Public Interest Litigation primarily based on the report of CAG and seeking investigation by the Central Bureau of Investigation (CBI) . The High Court held that CAG is not entitled to question the merits of the policy objectives of the State Government. The Supreme Court dismissed the appeal observing that though the CAG is a key figure in the system of Parliamentary control of finance but the report of the CAG is subject to scrutiny of the PAC and the Joint Parliamentary Committee.
