Courts cannot direct the filing of a charge-sheet but must ensure investigations conclude without unnecessary delay.

The petitioner filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) seeking the quashment of FIR No. 205/2024 registered at Police Station Civil Line, Datia, for offences under Sections 8 and 20 of the NDPS Act.

The FIR was lodged on 14.04.2024 following the seizure of cannabis plants from an agricultural field owned by the petitioner.

The petitioner contended that he does not cultivate the land personally, as it was leased to a "Bataidar" (working partner), and argued that the Investigating Officer (IO) had neither properly investigated his explanations nor filed a final report/charge-sheet, leaving the matter pending indefinitely.

During the hearing, the petitioner narrowed his prayer to a direction for the timely filing of the charge-sheet.

1. Whether the High Court, in the exercise of its inherent jurisdiction, can direct an Investigating Officer to file a specific report (charge-sheet or closure report).

2. Whether the delay in concluding the investigation violates the statutory mandate of timely investigation under the Code of Criminal Procedure/BNSS.

The Court relied on Section 173(1) of the Code of Criminal Procedure (CrPC), which mandates that every investigation shall be completed without unnecessary delay.

It further applied the precedent established in *D. Venkatasubramaniam v. M.K. Mohan Krishnamachari* (2009) 10 SCC 488, which holds that criminal investigation is the exclusive domain of the police and that courts exercising inherent jurisdiction (under Section 482 CrPC/Section 528 BNSS) must refrain from interfering with or supervising the manner of investigation to maintain the separation of powers.

The Court reasoned that while the petitioner's claims regarding non-cultivation are matters of fact to be examined during the investigation, the judiciary cannot dictate the outcome of that investigation (i.e., ordering a charge-sheet) as it would constitute "impermissible supervision".

However, the Court balanced this by highlighting the statutory obligation of the police to not keep matters pending indefinitely.

Applying the principle of timely justice, the Court determined that the IO is bound by law to conclude the proceedings within a "reasonable time" to prevent the abuse of the legal process.

It directed the Investigating Officer to conclude the investigation and take all consequential steps in accordance with law, preferably within one month from the date of the order.

The petition was disposed of with liberty granted to the petitioner to approach the concerned Magistrate or Superintendent of Police if grievances persist.