High Court cannot direct arrest or filing of charge-sheet under Section 482 CrPC.

The petitioner filed an application under Section 482 of the Code of Criminal Procedure (Cr.P.C.) seeking a direction from the High Court to the respondent authorities to arrest the accused named in Crime No. 0157/2025 (Police Station Daboh, District Bhind), complete the investigation, and submit a final report or charge-sheet before the competent court within a stipulated timeframe

1. Whether the High Court, in the exercise of its inherent powers under Section 482 of Cr.P.C., can issue specific directions to the police to arrest an accused and file a charge-sheet

2. Whether the Investigating Officer is legally mandated to complete the investigation without unnecessary delay under the statutory framework of the Cr.P.C.

The court primarily applied Section 173(1) of the Cr.P.C., which mandates that every investigation must be completed without "unnecessary delay"

It further relied on the precedent established by the Supreme Court in D. Venkatasubramaniam v. M.K. Mohan Krishnamachari (2009), which held that courts should not interfere with or guide the investigating agency’s discretion regarding the manner of investigation, arrest, or the filing of a charge-sheet

Additionally, the court cited M.C. Abraham v. State of Maharashtra (2003), establishing that arrest is a discretionary power of the police and not a mechanical requirement upon the lodging of an FIR

The court reasoned that it cannot supervise the investigation or issue a mandate to file a charge-sheet, as such actions fall within the exclusive statutory domain of the police

Citing Supreme Court jurisprudence, the court noted that the power of arrest is discretionary and should be exercised with circumspection, rather than under judicial compulsion

Furthermore, the court observed that interfering without hearing the affected accused parties would violate principles of natural justice and could lead to "drastic consequences"

However, the court emphasized that while it cannot direct a specific outcome (like an arrest), the Investigating Officer is legally bound by Section 173(1) of the Cr.P.C. to conclude the investigation as early as possible and determine whether an offence is made out

However, it disposed of the petition by observing that the Investigating Officer is expected to conclude the investigation and submit a final report (closure or charge-sheet) without unnecessary delay in accordance with the mandate of Section 173(1) of Cr.P.C.

The petitioner was granted liberty to approach the concerned Magistrate or Superintendent of Police for any surviving grievances