As per the case facts this writ petition concerns alleged massacres in villages in Chhattisgarh with petitioners claiming that the Chhattisgarh Police Special Police Officers Salwa Judum activists and Paramilitary ... Forces were responsible for brutal killings of tribals The petitioners sought a CBI investigation compensation for victims and the constitution of a Special Investigation Team SIT The appeal arose from these allegations with the State denying the 'massacre' connotation and claiming incidents were encounters with Naxalites The question arose whether the allegations of massacre by state forces warranted a CBI investigation or an SIT and if compensation should be paid to the victims Finally the Supreme Court after reviewing various reports and arguments did not explicitly order a CBI investigation or SIT but focused on the application of Section IPC stating that the bar under Section b applies even if a proceeding has concluded if the offense under Section IPC was committed in relation to that proceeding