Piecemeal charge sheet cannot defeat default bail when investigation into all FIR offences remains incomplete.

An incomplete or piecemeal charge sheet filed before completion of investigation into all offences in the FIR does not amount to a complete final report for the purpose of default bail under section 167(2) CrPC. The Court distinguished further investigation under section 173(8) from an incomplete investigation and held that further investigation is permissible only after a complete charge sheet has been filed. Because the filing covered only part of the allegations and left substantial issues pending, it could not be used to defeat the accused's indefeasible right to statutory bail linked to personal liberty under Article 21.

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Issues: Whether the filing of a piece-meal charge sheet before completion of investigation into all offences in the FIR defeated the petitioner's right to default bail under section 167(2) of the Code of Criminal Procedure, 1973.

Analysis: The Court held that the statutory scheme requires completion of the entire investigation in respect of all offences in the case before a final report under section 173 can be treated as complete for the purpose of section 167(2). It distinguished further investigation under section 173(8) from incomplete investigation and held that further investigation can follow only after a complete charge sheet has been filed. The charge sheet filed within time covered only part of the allegations and left substantial issues in the FIR pending, so it was treated as a piecemeal charge sheet. The Court further held that such a filing cannot be used to circumvent the indefeasible right to default bail, which is linked to personal liberty under Article 21.

Conclusion: The petitioner was entitled to statutory bail under section 167(2), and the request for default bail was allowed.

Ratio Decidendi: An incomplete or piecemeal charge sheet that does not conclude investigation into all offences in the FIR cannot defeat the accused's indefeasible right to default bail under section 167(2) of the Code of Criminal Procedure, 1973.

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