Investigation delay alone does not justify quashing an FIR where cross-border economic offences require continued inquiry.

Delay in investigation does not, by itself, justify quashing an FIR under inherent powers where the case concerns alleged manipulation of letters of credit and export-related offences. The court applied the settled position that there is no rigid outer time limit for completing an investigation; delay must be assessed in the factual context, with Article 21 rights balanced against the need for a fair and effective inquiry, especially in serious cross-border economic offences. As the record involved foreign documents, letters rogatory and requests to overseas authorities, and no substantial prejudice was shown, the investigation was treated as still at a crucial stage. The petition to quash was therefore not allowed.

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Issues: Whether delay in investigation, by itself, justified quashing of the FIR in exercise of inherent powers under Section 482 of the Code of Criminal Procedure, 1973, in a case involving alleged manipulation of letters of credit and export-related offences.

Analysis: The petition was founded primarily on the contention that the investigation had remained pending for an inordinately long period and that the continued inquiry amounted to abuse of process. The record showed that the investigation involved foreign-based documents, letters rogatory, and multiple requests for information from overseas authorities, including steps taken to secure material from New Zealand and other jurisdictions. The Court applied the settled principle that there can be no rigid outer time limit for completion of investigation and that delay must be examined in the factual context of each case. It also noted that while Article 21 protects the right to speedy investigation and trial, the Court must balance that right against the requirement of a fair and effective investigation, particularly in serious economic offences with cross-border elements. The petitioner had not demonstrated substantial prejudice flowing from the delay, and the investigation was still at a crucial stage.

Conclusion: Delay in investigation alone was not sufficient to quash the FIR, and the petition was not allowed.

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