Trial Court assessing bail cannot direct departmental enquiry or monitor investigation after becoming functus officio.

Following an FIR registered in 2019 under Section 363 IPC (later adding Sections 328/376 IPC and Section 4 POCSO Act) regarding a missing minor, several Investigating Officers (IOs) handled the case.

During the hearing of an anticipatory bail application filed by a co-accused, the learned Additional Sessions Judge (ASJ) noted delays in the investigation and, vide order dated 22.02.2022, called for status reports and directed the previous IOs and SHOs to appear in person.

Despite disposing of the bail application, the ASJ continued the proceedings, subsequently ordering departmental enquiries and seeking explanations from various police officials, including high-ranking IPS officers, for alleged supervisory lapses.

The Court relied on Section 439 of the Cr.P.C., asserting that jurisdiction is limited to the grant or refusal of bail.

It applied the principle from State v. M. Murugesan, which holds that courts cannot issue directions to "improve the system" under the color of a bail order.

Precedents including State of West Bengal v. Mir Mohammad Omar and Om Prakash Chautala v. Kanwar Bhan were cited to establish that disparaging remarks against officials should not be made without a hearing and are only permissible when absolutely necessary for adjudication.

Furthermore, State v. Yogender Singh established that monitoring disciplinary proceedings encroaches upon the administrative domain of the Police Department.

The High Court reasoned that the ASJ became functus officio the moment the anticipatory bail application was disposed of; consequently, retaining the matter on the board to monitor investigative delays was "completely unwarranted".

The Court observed that while the ASJ’s concern regarding investigative delay was laudable, the "means and manner" of directing departmental enquiries exceeded the court's statutory remit.

By passing adverse remarks and initiating enquiries without issuing notice to the petitioners, the ASJ violated the principles of natural justice.

The Court emphasized that a judge's function is to salvage justice despite investigative flaws, not to waste judicial time castigating officers for perfunctory investigations, especially when such officers are not parties to the bail plea.

The High Court allowed the petitions and set aside the impugned order dated 22.02.2022 and all consequential directions.

All adverse remarks against the petitioners were expunged.

The Court directed that the judgment be circulated to all District Judges to ensure Trial Courts refrain from similar judicial overreach in bail matters.