Further investigation in criminal trials may support supplementary witnesses; material gathered later can be used to unfold the prosecution case.

Further investigation under Section 173(8) of the Code of Criminal Procedure, 1973 is a continuation of the earlier investigation and may proceed after filing of the police report; it is not a fresh investigation or reinvestigation. Prior permission of the Magistrate is not mandatory for such further investigation, and material collected at that stage cannot be ignored merely because it is produced during trial. Section 231 also supports the prosecution's right to produce witnesses necessary to unfold its case, even if they were not examined earlier. The order permitting summoning of witnesses named in the supplementary charge-sheet was upheld, and the revision was dismissed.

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Issues: Whether, after filing of the charge-sheet and commencement of trial, the prosecution could rely on a supplementary charge-sheet arising from further investigation to summon additional witnesses.

Analysis: Section 173(8) of the Code of Criminal Procedure, 1973 permits further investigation after submission of the police report under Section 173(2), and such further investigation is a continuation of the earlier investigation. It does not amount to fresh investigation or reinvestigation, which is impermissible. The Court held that prior permission of the Magistrate is not mandatory for further investigation, and that the object of criminal process is to discover the truth and do substantial justice. The material collected in further investigation cannot be ignored merely because it is produced at the trial stage. Section 231 of the Code of Criminal Procedure, 1973 also supports the prosecution's right to produce witnesses necessary for unfolding its case, even if they were not examined earlier.

Conclusion: The order permitting summoning of the witnesses named in the supplementary charge-sheet was valid, and the revision was rightly dismissed.

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