New Delhi — The Supreme Court has ruled that a court cannot declare a criminal investigation complete merely because a prosecution filing says enough evidence exists to submit a chargesheet.
The case arose from a UAPA investigation in which Maharashtra’s Anti-Terrorism Squad sought a second 15-day extension to analyse electronic devices, forensic data, bank transactions and other material. The Bombay High Court treated one sentence in the extension application as showing that investigation was complete, invalidated the extension and granted default bail.
Justices Prashant Kumar Mishra and Shree Chandrashekhar reversed that decision. They said investigation is the police’s statutory domain and courts may interfere only in exceptional circumstances or where a legal bar exists. A complete chargesheet must explain how forensic and financial material connects an accused to the alleged offence; that analysis forms part of investigation.
The Court held that the High Court had diverted into whether prosecution sanction could justify more time, despite the ATS expressly seeking time to complete evidentiary analysis. It restored the Special Judge’s extension, dismissed the default-bail application and directed the surviving respondent to surrender within 30 days, while leaving regular bail open.
