Prolonged investigation in disproportionate assets cases does not warrant quashing if delay arises from factual complexity.

The Petitioner, a former Motor Vehicle Inspector, was charged under Section 13(2) r/w 13(1)(e) of the Prevention of Corruption Act, 1988, and Section 109 of the IPC following a 2016 search that allegedly revealed assets disproportionate to his known sources of income (₹1,74,74,110/-).

The Petitioner contended that the valuation included properties belonging to his father-in-law and ancestral estate.

Despite a 2024 High Court direction in a previous CRLMC to expedite the probe and exclude non-contributed assets, the Petitioner sought quashing of the proceedings on the grounds of a decade-long delay (violating Article 21) and failure of the agency to follow judicial directions.

During the pendency of this petition, the investigating agency completed the probe and submitted a charge-sheet.

1. Whether the prolonged pendency of the investigation (nearly ten years) constitutes a violation of the right to a speedy trial under Article 21 sufficient to quash the proceedings.

2. Whether the investigating agency failed to comply with the court's prior directions regarding the exclusion of third-party assets from the disproportionate assets computation.

3. Whether the High Court, under Section 482 of the Cr.P.C. (Section 528 of BNSS), can adjudicate disputed questions of fact regarding the ownership and source of alleged assets.

The court primarily applied Section 482 of the Criminal Procedure Code, 1973 (corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023) regarding the High Court's inherent power to prevent abuse of process.

The court relied on the Constitutional mandate of Article 21 for a speedy trial but noted that delay must be evaluated contextually.

It followed the principles in A.R. Antulay v. R.S. Nayak and Niranjan Hermchandra Sashittal v. State of Maharashtra, holding that no fixed time limit can be set for complex economic offences like corruption, as they require meticulous scrutiny of camouflaged assets.

The court reasoned that the decade-long delay was not "deliberate or mala fide" but was necessitated by the complexity of verifying international fund transfers (from the USA), multi-district property records, and disruptions caused by the COVID-19 pandemic.

The court observed that the investigating officer had, in fact, complied with the 2024 judicial directions by re-assessing the assets and representations prior to filing the charge-sheet.

Crucially, the court noted that once a charge-sheet is filed, the argument of "perpetual stagnation" fails.

The Petitioner’s claims regarding independent business income and third-party ownership of flats and vehicles were deemed "intrinsically factual," requiring a "mini-trial" which is impermissible under Section 482.

The court declined to exercise its inherent jurisdiction, ruling that disputed factual defenses regarding the source of income must be adjudicated by the trial court during a full-fledged trial and all interim orders were vacated.