Transfer of investigation to an independent agency requires rare, case-specific justification; generalized bias allegations were insufficient here.

Transfer of investigation to a central or independent agency is an extraordinary power to be used sparingly and only in rare cases where a fair investigation or public confidence cannot otherwise be secured, or where State investigation is shown to be biased. The petitioner sought wholesale transfer of numerous FIRs, including future cases, but the Court found no material showing that the State police or machinery were tainted against the petitioner. Broad relief cannot be granted on generalized allegations, and each case must be assessed on its own facts. The request for transfer was therefore rejected and the writ petition dismissed.

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Issues: Whether the investigation of the large number of FIRs registered against the petitioner and other members of GJM should be transferred en masse to an independent agency under Article 32.

Analysis: Transfer of investigation to a central or independent agency is an extraordinary power to be exercised sparingly, cautiously and only in rare and exceptional cases where it is necessary to secure a fair investigation, instil public confidence, or where the State investigation is shown to be tainted or biased. The petitioner sought transfer of all FIRs collectively, including future cases, but the record disclosed serious allegations of violence, arson, public disorder and offences against life and property. The Court held that such broad relief cannot be granted in the abstract or on generalized allegations of bias. Each case has to be considered on its own facts, and the petition did not disclose material showing that the State police or State machinery were biased against the petitioner in a manner justifying wholesale transfer of investigation. The Court also distinguished precedents where transfer had been ordered at the instance of victims in specific factual settings.

Conclusion: The request for transfer of investigation was rejected and the writ petition was dismissed.

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