Supplementary criminal investigation reports must be received after cognizance and assessed later at charge or discharge stage.

A supplementary report under Section 173(8) CrPC may be filed after further investigation even after cognizance has been taken on the main charge-sheet. Once cognizance rests on the original report, the court need not take cognizance again on the supplementary report; instead, it must receive the additional material and consider its effect at the stage of charge or discharge. The trial court cannot reject the supplementary report at the threshold merely because it believes the material may not yet disclose an offence. The orders refusing reception were set aside, and the supplementary material was directed to be considered with the pending discharge applications.

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Issues: Whether a supplementary report filed under Section 173(8) of the Code of Criminal Procedure, 1973 can be refused reception or rejected at the threshold after cognizance has already been taken on the main charge-sheet.

Analysis: Section 173(8) preserves the power of further investigation after the report under Section 173(2) has been forwarded, and the officer-in-charge may submit a further report based on fresh material. Once cognizance has already been taken on the main report, the court is not required to take cognizance again on the supplementary report. The supplementary report is only an additional report in aid of the earlier report, and the truth or sufficiency of the allegations contained in it is a matter for consideration at the later stage of framing of charge or discharge. The trial court, therefore, cannot reject such a report outright merely because it considers that the material may not yet disclose an offence.

Conclusion: The supplementary report had to be received on record, and the accused were entitled to seek discharge in respect of the allegations contained in it in accordance with law.

Final Conclusion: The orders refusing to receive the supplementary report were set aside, and the Special Court was directed to consider the supplementary material along with the pending discharge applications.

Ratio Decidendi: A supplementary report under Section 173(8) of the Code of Criminal Procedure, 1973 cannot be rejected outright once cognizance has already been taken on the main report, and it must be received for consideration at the appropriate stage.

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