Virginia Code

Va. Code Ann. § 48-1 (2026)

Investigation of complaint by special grand jury

✓ current as of May 2026
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When complaint is made to the circuit court of any county, or the corporation court of any city of this Commonwealth, by five or more citizens of any county, city or town, setting forth the existence of a public or common nuisance, the court, or the judge thereof in vacation, shall summon a special grand jury, in the mode provided by law, to the next term of such court, to specially investigate such complaint.

Code 1919, § 1520.

Notes of Decisions
Cited in 7 cases (3 in the last 5 years), 1993–2024 · leading case: Manning v. Caldwell for City of Roanoke, 930 F.3d 264 (4th Cir. 2019).
Manning v. Caldwell for City of Roanoke, 930 F.3d 264 (4th Cir. 2019). “The consequences of such a venture are boundless. Many civil statutes make use of imprecise phrases.”
Jordan v. Commonwealth, 549 S.E.2d 621 (Va. Ct. App. 2001). · cites it 2× “It authorizes a special grand jury to investigate a complaint of nuisance made by five citizens, Code § 48-1, and to make a presentment against the person who created or caused the *275 nuisance, Code § 48-2.”
Field v. Kroger Ltd. P'ship I (E.D. Va. 2021). · cites it 3× “See Va. Code § 48-1 et seq.; Jordan v. Commonwealth, 549 S.”
Michael J. Muhammad v. Ramin Fatehi (Va. Ct. App. 2024). · cites it 2× “Most relevant to this appeal, he also sought to impose sanctions as the complaint was not “well 2 Code § 48-1 reads: When complaint is made to the circuit court of any county, or the corporation court of any city of this Commonwealth, by five or more citizens of any county, city…”
Saifullah K. Niazi v. Commonwealth of Virginia (Va. Ct. App. 2004). · cites it 2× “Saifullah Niazi of causing or creating a public nuisance, Code §§ 48-2 and 48-5, and of permitting the continuation of a public nuisance, Code §§ 48-1 and 48-6. Dr. Niazi contends that the trial judge committed five errors: (1) ruling that a limitation on testimony could cure…”
Christina F. v. Jason C. (2024). “Va. Code § 48-1 - 235.4 (2001) (emphasis added).”
Afton Place Assocs., L.P. v. Richmond Redevelopment & Hous. Auth., 31 Va. Cir. 322 (Richmond County Cir. Ct. 1993). · cites it 2× “Section 48-1 et seq. has been violated, so as to constitute negligence per se.”
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