CBI Investigation Transfer requires exceptional grounds; completed police investigation and filed charge sheet were held insufficient

Transfer of a criminal investigation to an independent agency is justified only in rare and exceptional cases where the existing investigation is shown to be unfair, incomplete, or lacking credibility. Where the State police have already arrested the accused, collected material evidence, and filed the charge sheet, the normal course is for the trial to proceed, and mere allegations or suspicion are insufficient to warrant CBI intervention. Applying that principle, the request for transfer was rejected, the petition was dismissed, and the trial court was left to proceed in accordance with law, including consideration of any request to summon additional accused if the evidence permits.

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Issues: Whether the investigation of the criminal case should be transferred to the Central Bureau of Investigation.

Analysis: The extraordinary power to direct investigation by an independent agency is to be exercised sparingly and only in rare and exceptional cases where the existing investigation lacks credibility, fairness, or completeness, or where such intervention is necessary to secure justice and public confidence. Where the State police has already conducted the investigation, arrested the accused, collected material evidence, and filed the charge sheet, the normal course is to allow the trial to proceed. Mere allegations, suspicion, or unsubstantiated apprehension against local police or political figures are not enough to justify transfer of investigation. The existence of some additional material or further allegations does not, by itself, establish that the investigation was unfair or incomplete.

Conclusion: The request to transfer the investigation to the CBI was not warranted and was rejected.

Final Conclusion: The petition was dismissed, and the trial court was left to proceed in accordance with law, including consideration of any request to summon additional accused if the evidence so permits.

Ratio Decidendi: Direction for CBI investigation can be issued only in exceptional cases on a showing of inadequate or unfair investigation, and not merely on the basis of allegations where the police investigation has already been substantially completed and charge sheet filed.

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