Default bail survives a partial charge-sheet when investigation into the full FIR remains incomplete under statutory timelines.

A charge-sheet filed within the statutory period does not defeat default bail unless it completes investigation of the entire FIR and all connected offences. A piece-meal report covering only part of the allegations cannot be treated as full compliance with Section 167(2) of the Code of Criminal Procedure, and further investigation cannot be used to fragment one FIR into multiple reports to bypass the right to statutory bail. The incomplete charge-sheet did not alter the consequence of non-completion of investigation, and the absence of sanction or cognizance did not change the result. The applicant was therefore entitled to default bail.

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Issues: Whether the applicant was entitled to statutory bail under Section 167(2) of the Code of Criminal Procedure, 1973 on the ground that the charge-sheet filed within 60 days was only a piece-meal report and investigation into other offences in the FIR remained incomplete.

Analysis: The Code contemplates completion of the entire investigation in the case before a final police report is filed. A report that covers only part of the allegations in the FIR, while leaving substantial connected allegations for later investigation, cannot be treated as full compliance with Section 167(2). The distinction between completion of investigation and further investigation is material: further investigation can follow only after a complete report is filed, and it cannot be used to justify fragmenting one FIR into multiple charge-sheets to defeat the right to default bail. The filing of the charge-sheet on the 46th day covered only part of the allegations and did not conclude the investigation into all offences stated in the FIR. The absence of sanction and non-taking of cognizance did not alter the consequence under Section 167(2).

Conclusion: The applicant was entitled to default bail, and the plea of the investigating agency that filing of the partial charge-sheet defeated that right was rejected.

Ratio Decidendi: A charge-sheet filed within the statutory period does not defeat default bail unless it reflects completion of the investigation in respect of the entire case and all offences arising from the FIR; a piece-meal report cannot be used to circumvent Section 167(2) of the Code of Criminal Procedure, 1973.

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