Final report under criminal procedure can still stand despite further investigation, defeating statutory bail under Section 167(2).

A charge-sheet can qualify as a final report under the Code of Criminal Procedure where it reflects the investigation already completed on the examined facets and is sufficiently complete to enable the Special Court to take cognizance. The mere fact that further verification or additional investigation remains pending does not, by itself, change its character as a final report. Because the requisite sanctions under the special statutes had been obtained and Section 167(2) was treated as complied with, the petitioners were not entitled to statutory bail.

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Issues: Whether the charge-sheet filed by the investigating agency was a final report within the meaning of the Code of Criminal Procedure so as to defeat the claim for statutory bail under Section 167(2).

Analysis: The materials already investigated were reflected in the charge-sheet, and the report disclosed a completed investigation on the facets then examined. The fact that some further verification or additional investigation remained to be done did not, by itself, convert the report into something other than a final report. The requisite sanctions under the special statutes had also been obtained, and the report was complete enough to enable the Special Court to take cognizance. In these circumstances, Section 167(2) of the Code of Criminal Procedure was held to have been complied with.

Conclusion: The petitioners were not entitled to statutory bail.

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