Police report completeness under CrPC turns on Section 173(2), not on annexing the CFSL report for default bail.

A police report is complete for default-bail purposes when it satisfies Section 173(2) of the CrPC and contains the required particulars about the parties, the information, witnesses, and whether an offence appears to have been committed. The absence of a CFSL report or other evidentiary documents to be forwarded under Section 173(5) does not by itself make the challan incomplete, because that duty is separate and supports supply of documents under Section 207. On that basis, the challan was treated as valid in law and no right to default bail arose merely because the CFSL report was not filed with it.

---

---

Issues: Whether a challan filed within the statutory period under the Code of Criminal Procedure, 1973 is incomplete merely because the CFSL report is not appended to it, and whether such omission entitles the accused to default bail under Section 167(2).

Analysis: The Court read Sections 167(2) and 173(2) of the Code of Criminal Procedure, 1973 together and held that the test of completion of investigation is whether the police report contains the particulars required by Section 173(2). The report becomes complete when the investigation has been concluded and the officer can forward the report with the necessary particulars as to the parties, the nature of the information, the witnesses, and whether an offence appears to have been committed. The CFSL report was treated as part of evidentiary material, but not as a component essential to the completion of the police report itself. The Court further held that the obligation under Section 173(5) to forward documents on which the prosecution proposes to rely is an additional duty meant to facilitate compliance with Section 207, and its absence does not render the police report incomplete for the purpose of Section 167(2). Section 173(7) was also relied upon to show that the forwarding of such documents is not of the same mandatory character as the completion of the report under Section 173(2).

Conclusion: The challan was complete in law, and the accused did not become entitled to default bail on the expiry of the 90-day period.

Final Conclusion: The bail application failed because non-filing of the CFSL report with the challan did not invalidate the police report or create an enforceable right to release on bail under the default-bail provision.

Ratio Decidendi: A police report is complete for the purpose of Section 167(2) when it satisfies Section 173(2); omission to annex evidentiary documents required to be forwarded under Section 173(5) does not by itself make the report incomplete or trigger default bail.

---