Limited safeguards during investigation: written summons, diary recording, and anti-harassment directions were ordered without halting enquiry.

Inherent jurisdiction should not normally be used to interfere with the mode of investigation, which remains within the investigating officer's domain, but complaints of harassment during enquiry cannot be ignored. The Court therefore issued limited protective directions: persons summoned for enquiry or investigation must be called through written summons under Section 160 CrPC specifying the date and time, the minutes of enquiry must be recorded in the relevant diary, and investigating officers must avoid harassment. It also required compliance with the Supreme Court guidelines on preliminary enquiry and FIR registration. No general interference with the pending enquiry or investigation was granted.

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Issues: Whether the Court should interfere under its inherent jurisdiction to prevent harassment during enquiry or investigation and issue safeguards for summoning persons named in a complaint.

Analysis: The petition complained of harassment under the guise of enquiry. The Court reiterated that investigation is ordinarily within the unfettered domain of the investigating officer and that interference with the mode of investigation is not normally warranted under the inherent jurisdiction. At the same time, the Court recognized that allegations of harassment during investigation cannot be ignored. To address such complaints, it directed that persons summoned for enquiry or investigation be called through written summons under Section 160 of the Code of Criminal Procedure, 1973, with a specified date and time, that the minutes of enquiry be recorded in the relevant diary, and that investigating officers refrain from harassment. It also directed adherence to the Supreme Court guidelines on preliminary enquiry and registration of FIR.

Conclusion: Limited protective directions were issued in the petitioner's favour, but no general interference with the pending enquiry or investigation was granted.

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