Further investigation cannot be ordered merely to seek a different view of the same evidence.

The petitioner, mother of the deceased and de facto complainant, sought further investigation by another competent officer into the final report in S.C.No.120 of 2025.

Her son was murdered on 27 July 2025; four persons were initially charged, including the alleged assailant, his parents and a relative.

The investigation was transferred from the local police to the CBCID on 30 July 2025, and the final report was filed on 4 November 2025.

The petitioner alleged bias by the local police, inadequate investigation into the parents’ alleged involvement and possible conspiracy, failure to examine the deceased’s phone or scrutinise call-detail records, and inadequate communication with her as a victim.

The State submitted that the CBCID had conducted a comprehensive investigation, examined 70 witnesses and filed its report; A3 was subsequently arrested.

Whether the petitioner had established grounds for directing further investigation by another officer after the CBCID filed its final report.

Whether the alleged failure to examine the deceased’s mobile phone and the asserted shortcomings in informing the petitioner warranted such a direction.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, was invoked as the basis for the High Court’s inherent jurisdiction to consider the requested direction.

Section 358 of the BNSS empowers the Trial Court, on evidence emerging during trial, to proceed against a person who appears to be connected with the offence, even if that person is not then facing trial.

Section 15-A of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989, confers substantive rights of information and participation on a victim; a shortfall in providing information, however, does not by itself require further investigation.

The judgment identifies no precedent or more specific legal test for ordering further investigation.

The Court found that the local-police bias allegation was substantially answered by the prompt transfer of the investigation to the CBCID, and no case was made out that the CBCID continued any biased investigation.

The investigation had examined the conduct of A2 and A3, arrayed them as accused, and resulted in a final report after witness examination and recovery of material objects.

The petitioner’s central complaint was that the Investigating Officer had not treated their conduct as criminal conspiracy, rather than that identifiable evidence remained uninvestigated; she pointed to no additional witness, document or scientific test that further investigation would produce.

The Court held that the deceased’s phone could still be the subject of an application by the prosecution before the Trial Court, while the failure to keep the petitioner informed was regrettable but did not justify further investigation.

The Trial Court’s power under Section 358 BNSS remained available if evidence at trial implicated others.

It disposed of the petition with observations, without precluding the prosecution from seeking forensic examination of the deceased’s phone or affecting the Trial Court’s power under Section 358 BNSS.