Police officer acting as investigator not invalid per se; bias must be shown on the facts.

An investigation is not invalid merely because the same police officer received the information, conducted the search, registered the case and then investigated it. The controlling principle is that such a process can be challenged only on proof of bias or a real likelihood of bias on the facts. Here, the officer acted in an official capacity, recovered contraband and proceeded with the case, but no circumstance showing prejudice or personal interest was established. The investigation was therefore not vitiated, and the conviction was upheld.

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Issues: Whether the investigation was vitiated because the police officer who received the information, conducted the search, registered the case and filed the charge-sheet was also the investigating officer.

Analysis: The challenge was examined on the footing that a complaint by the officer who later investigates may, in some circumstances, affect fairness. The governing principle applied was that such investigation is not invalid per se; it can be questioned only if there is bias or a real likelihood of bias on the facts of the case. On the facts found, the officer acted in an official capacity, recovered the contraband, registered the case and proceeded with the investigation, but no circumstance showing prejudice or personal interest was established.

Conclusion: The investigation was not vitiated and the conviction was upheld against the appellants.

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