Supervisory power over criminal investigation upheld where the probe was tardy and ineffective, preventing miscarriage of justice.

Criminal investigation ordinarily remains within the investigating agency's domain, and courts should not interfere in its course as a routine matter. Constitutional courts may, however, exercise supervisory power in exceptional cases where the investigation is stalled, tardy, or at risk of being compromised, and intervention is necessary to secure a fair investigation and prevent miscarriage of justice. On the stated facts, the High Court intervened because the investigation had been slow and ineffective, repeated reports had been sought, and the authorities had not acted with sufficient seriousness until monitored. The High Court's monitoring order was therefore upheld.

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Issues: Whether the High Court could monitor an ongoing criminal investigation and require periodic progress reports and further steps where the investigation was found to be tardy and ineffective.

Analysis: Investigation of an offence ordinarily remains within the domain of the investigating agency, and courts should not interfere in the manner or course of investigation as a routine matter. However, the constitutional courts retain supervisory power in exceptional situations where the facts disclose that the investigation is not progressing properly or may be adversely affected, and intervention is necessary to prevent miscarriage of justice. On the facts, the High Court intervened because the investigation had been slow, repeated reports had been sought, and the authorities had not been proceeding with sufficient seriousness until monitored.

Conclusion: The High Court was justified in monitoring the investigation, and the challenge to its orders failed.

Ratio Decidendi: Courts may supervise or monitor a criminal investigation in exceptional cases where the investigation is stalled, tardy, or otherwise at risk of being compromised, if such intervention is necessary to secure a fair investigation and prevent miscarriage of justice.

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