The Supreme Court has ruled that lower courts should generally refrain from imposing strict deadlines on investigative agencies, emphasizing the importance of allowing them the freedom to conduct probes effectively. A bench of Justices Sanjay Karol and N Kotiswar Singh noted that setting timelines for the completion of investigations should be reserved for cases involving undue delay or those where the liberty of citizens is adversely affected. The court underscored that such timelines should be the exception, not the norm.
In a recent judgment, the Supreme Court overturned an order by the Allahabad High Court that had directed the police to conclude an investigation into arms license forgery within three months. This decision serves as a reminder to high courts to maintain awareness of the practical challenges inherent in investigations, advocating for a balanced approach where time-bound probes are imposed cautiously. The Supreme Court has made it clear that imposing timelines should be a reactive measure to address delays or stagnation, rather than a proactive measure.
The court acknowledged that legal proceedings frequently intersect with investigations, influencing their pace and direction. It was observed that investigations can be unpredictable, likening them to a "long, winding road". Various factors can contribute to delays, such as witnesses hesitating or retracting statements, documentary evidence proving unusable, or investigating agencies facing applications for anticipatory bail.
The Supreme Court has consistently recognized that directing a time-bound investigation must remain the exception rather than the norm. Instances where the court has intervened by setting timelines include cases with evident stagnation in the probe, unexplained inaction, or a pattern of delay not justified by the case's nature or complexity. The court has also been mindful of the impact of prolonged investigations on personal liberty, particularly when coercive measures or extended custody are involved.
In the specific case that prompted the ruling, the Supreme Court set aside decisions by the Allahabad High Court related to three accused individuals under investigation for obtaining arms licenses through forged documents. While the state police had initiated the probe in May, the High Court directed its completion within 90 days and granted the accused protection from arrest until the trial court took cognizance of the police charge sheet.
The Supreme Court's observations serve as a guide for lower courts, emphasizing the need to consider the practical realities of investigations and to impose timelines judiciously, primarily in cases of unwarranted delay or potential infringement on personal liberty. The ruling reinforces the principle that investigative agencies should generally be afforded the necessary freedom to conduct thorough and effective probes.
