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Issues: Whether, after completion of investigation by the Special Investigation Team, the Court should continue to monitor the matter and whether the final report must be forwarded to the competent court in accordance with the Code.
Analysis: Once the investigation monitored by the Court had been completed, the scheme of Chapter XII of the Code required the investigating agency to submit its final report under Section 173 to the court empowered to take cognizance. The Court's supervisory role in a monitored investigation was confined to ensuring proper investigation and did not extend to taking over the functions of the Magistrate after filing of the final report. If the report were to be a closure report, the complainant had to be issued notice and supplied the relevant material before a final decision was taken on such report, in accordance with the settled procedure.
Conclusion: The monitoring by the Court was brought to an end, and the Special Investigation Team was directed to forward the final report with the collected material to the competent court for proceedings in accordance with law.
Ratio Decidendi: After completion of a monitored investigation, the Court's continuous supervisory jurisdiction ends, and the competent Magistrate alone must deal with the final report and further proceedings under Section 173 of the Code, including notice to the informant where a closure report is proposed.