Investigating officers must complete investigations without unnecessary delay and file the final report.

The petitioner approached the High Court under Article 226 of the Constitution seeking directions for a fair, impartial, and expeditious investigation in FIR No. 214/2026, registered at Police Station Juni, Indore, under Sections 115(2), 351(3), 296(b), and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

He alleged that the police had not concluded the investigation or filed the appropriate final report and had proceeded with a cross-FIR while leaving his FIR pending without justification.

The petitioner sought, inter alia, consideration of all evidence, examination of the investigation records relating to FIR Nos. 214/2026 and 215/2026, and a time-bound investigation.

Whether the police could be directed to conclude the investigation in FIR No. 214/2026 without unnecessary delay and file the appropriate final report before the competent court?

Whether the High Court should issue directions concerning the manner or scope of the investigation, including consideration of particular evidence or comparison with the cross-FIR?

The Court applied Section 193(1) of the Bharatiya Nagarik Suraksha Sanhita, 2023, which mandates that every investigation be completed without unnecessary delay.

It relied on D. Venkatasubramaniam v. M.K. Mohan Krishnamachari, (2009) 10 SCC 488, which holds that investigation is primarily within the statutory domain and duty of the police, and that courts should ordinarily not interfere with or direct the investigating agency as to the manner in which the investigation must proceed.

The precedent further recognises that an investigation may result either in a charge-sheet or a closure report, and that arrest, seizure, or filing of a charge-sheet is not inevitable in every case.

The Court recognised that the police had a statutory obligation under Section 193(1) BNSS to bring the investigation to a conclusion without unnecessary delay and to determine whether an offence was made out.

At the same time, relying on D. Venkatasubramaniam, it acknowledged that the High Court should not supervise or dictate the investigative process, require particular investigative steps, or direct the police to proceed from a specified angle.

Accordingly, rather than directing the police to accept the petitioner’s version, consider specific evidence in a particular manner, or prefer FIR No. 214/2026 over the cross-FIR, the Court issued a general direction requiring completion of the investigation and filing of the legally appropriate final report—whether a charge-sheet or closure report—within a specified period.

The Investigating Officer was directed to conclude the investigation in FIR No. 214/2026 as early as possible, take all necessary steps in accordance with law, and file the final report before the competent court preferably within two months from receipt of the certified copy of the order.

The Court did not direct the police to adopt any particular investigative method or conclusion.

The petitioner was granted liberty, in case of any grievance, to approach the Superintendent of Police, District Indore, who was directed to consider the grievance in accordance with law.