CBI jurisdiction and further investigation upheld where consent notification needed no recorded reasons and no hearing right existed.

A statutory notification extending Delhi Special Police Establishment jurisdiction need not record reasons on its face, because Sections 5 and 6 of the Delhi Special Police Establishment Act, 1946 do not require the reasons for consent or extension to be stated in the notification; the notification was therefore not invalid on that ground. The accused has no vested right to be heard on the choice of investigating agency, and natural justice does not apply to that decision. Further investigation by the CBI was permissible under Section 173(8) of the Code of Criminal Procedure, 1973 where the earlier police investigation was unsatisfactory and the final report had not yet been accepted.

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Issues: (i) whether a notification extending the powers and jurisdiction of the Delhi Special Police Establishment to a specified case and State must record reasons on its face; (ii) whether the accused has any right to be heard on the choice of investigating agency and whether principles of natural justice apply to such a decision; (iii) whether further investigation by the CBI could validly proceed in the facts of the case.

Issue (i): whether a notification extending the powers and jurisdiction of the Delhi Special Police Establishment to a specified case and State must record reasons on its face

Analysis: The power to consent to, and extend, the jurisdiction of the Delhi Special Police Establishment under Sections 5 and 6 of the Delhi Special Police Establishment Act, 1946 was treated as a statutory administrative decision. The Court held that no provision required the reasons for granting consent or extending jurisdiction to be stated in the notification itself. The existence or sufficiency of reasons could be shown independently if necessary.

Conclusion: The notification was not invalid merely because it did not contain reasons.

Issue (ii): whether the accused has any right to be heard on the choice of investigating agency and whether principles of natural justice apply to such a decision

Analysis: The Court held that the decision as to who should investigate an offence does not attract the principles of natural justice. An accused person has no vested right to demand that a particular agency investigate the offence, and cannot insist on participation in the decision selecting the investigating agency.

Conclusion: The accused had no right to be heard, and the challenge on natural justice grounds failed.

Issue (iii): whether further investigation by the CBI could validly proceed in the facts of the case

Analysis: The record showed that the local police investigation had not been satisfactory and that the final report was still pending acceptance. The Court treated the CBI investigation as a further investigation, which is permissible under Section 173(8) of the Code of Criminal Procedure, 1973. The absence of acceptance of the earlier report supported the legality of the subsequent investigation.

Conclusion: Further investigation by the CBI was legally permissible.

Final Conclusion: The order quashing the consent and extension notifications was set aside, and the challenge to the CBI investigation failed.

Ratio Decidendi: A statutory consent order extending CBI jurisdiction need not record reasons on its face, the accused has no enforceable right to be heard on the choice of investigating agency, and further investigation is permissible where the law so allows.

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