Criminal investigation stays are exceptional; interim protection inconsistent with Neeharika principles was vacated.

A court should not stay a criminal investigation in proceedings under Article 226 or Section 482 CrPC except in the rarest of rare cases. Applying the caution mandated in Neeharika Infrastructure, the Supreme Court found that the High Court had wrongly granted interim protection staying further investigation and criminal proceedings despite an earlier order setting aside similar relief in the same matters. The interim order was therefore vacated, and the appeals were allowed.

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Issues: Whether the interim order staying further criminal proceedings and investigation in proceedings under Article 226 of the Constitution read with Section 482 of the Code of Criminal Procedure, 1973 was liable to be set aside.

Analysis: The proceedings arose from a challenge to criminal investigations, and the High Court had again granted interim relief staying further investigation despite an earlier order of the Supreme Court setting aside similar interim protection. The Supreme Court noted that the principles laid down in Neeharika Infrastructure require extreme caution before staying an investigation, and that such restraint is justified only in the rarest of rare cases. The Court held that the High Court had not properly appreciated those principles and had erred in granting the same interim protection again, which was contrary to the earlier directions in the very same criminal matters.

Conclusion: The interim order staying investigation and further criminal proceedings was set aside, and the appeals were allowed.

Ratio Decidendi: A court should not stay a criminal investigation in proceedings under Article 226 or Section 482 of the Code of Criminal Procedure, 1973 except in the rarest of rare cases, and any interim protection inconsistent with that standard is liable to be vacated.

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