Further investigation after charge sheet does not stall framing of charge absent fresh material against the accused.

Further investigation may continue after filing of a charge sheet, and that power is not extinguished merely because the matter has reached the stage of framing charge. A supplementary report forms part of the final report, but reinvestigation is not permitted. Where no fresh material has emerged against the accused and the continuing inquiry relates mainly to co-accused persons, the trial need not be kept in abeyance on the basis of speculative future information. If later fresh material arises, the prosecution may seek permission for further investigation in accordance with law.

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Issues: Whether the trial ought to be stalled because further investigation was stated to be continuing, and whether the observations in the earlier precedent on further investigation bound the court below so as to require deferment of framing of charge.

Analysis: The governing principle is that the police retain power to further investigate even after filing of the charge sheet, and such power is not lost merely because trial has reached the stage of framing of charge. The earlier precedent relied upon by the petitioner was noticed, but the core question there was different. The court also referred to other authorities which recognise that a supplementary report forms part of the final report and that further investigation is permissible, though reinvestigation is not. On the facts, the investigation as against the petitioner had already resulted in charge-sheet and supplementary charge-sheet, and the only continuing inquiry was directed mainly towards co-accused persons abroad. No fresh material against the petitioner had emerged, and the possibility of future information from foreign authorities was speculative. In such circumstances, the trial could not be kept in abeyance.

Conclusion: The challenge to continuation of the trial failed, and the petitioner's request to stall framing of charge was rejected. The court held that if fresh material later emerges, the prosecution may seek permission for further investigation in accordance with law, but the present trial must proceed.

Ratio Decidendi: Further investigation under the criminal procedure law may continue even after filing of the charge sheet, but it does not justify stalling trial or framing of charge in the absence of fresh material relevant to the accused concerned; any later fresh material must be brought before the court for appropriate permission and consideration.

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