Judicial restraint bars courts from turning a narrow writ case into policy directions on investigation and administration.

Judicial review in a writ proceeding must stay confined to the lis before the court and cannot be expanded into general policy directions on police investigation, prosecution structure, forensic facilities, staffing, or statewide administrative matters. The Supreme Court held that such directions, when unrelated to the limited criminal complaint under consideration, amount to judicial overreach and trench upon legislative and executive functions. Emphasising judicial restraint and separation of powers, the Court reiterated that courts cannot assume the role of policy-maker or direct law-making or administrative restructuring. The High Court therefore exceeded its jurisdiction in issuing the impugned directions, and its order was liable to be set aside.

---

---

Issues: Whether the High Court could, in a writ proceeding concerning a limited criminal complaint, issue wide-ranging directions touching police investigation, prosecution structure, forensic facilities, staffing, and matters lying in the legislative or executive domain.

Analysis: The Court held that judicial review must remain confined to the controversy before the court and cannot be converted into a platform for general comments or policy-making. Directions for creating specialized cadres, altering prosecutorial structure, prescribing qualifications for investigators, expanding forensic infrastructure, or seeking affidavits on statewide administrative questions were found to be unrelated to the lis and beyond the proper scope of adjudication. The Court emphasised judicial restraint, the separation of powers, and the settled principle that courts cannot assume legislative or executive functions or direct the making of law or policy.

Conclusion: The High Court had exceeded its jurisdiction in issuing the impugned directions, and the order was liable to be set aside.

---