Ongoing investigation and limited use of police diaries justify judicial restraint on premature interference and adverse comments.

Ongoing investigation should ordinarily not be disrupted by premature judicial directions or adverse comments, because statements to police and police diary material have only limited use at trial under Sections 162 and 172 CrPC. Disclosure of diary records and interference with investigative steps were considered premature while the inquiry remained in progress. Courts should avoid orders that may hamper, derail, or demoralise an active investigation, and the investigating agency must be allowed to act efficiently and vigilantly without pressure. On that basis, the challenge to the High Court's order was rejected and no relief was granted.

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Issues: Whether the Court should interfere with the appellate order of the High Court or make directions/comments affecting an investigation that was still in progress.

Analysis: The investigation was continuing and only limited use can be made of statements to the police and police diaries even at trial, as reflected in Sections 162 and 172 of the Code of Criminal Procedure, 1973. In that setting, disclosure of diary material and adverse comments on the manner of investigation were premature. Courts should ordinarily avoid interventions that may hamper, derail, or demoralise an ongoing investigation. The directions issued to the Director of the Central Bureau of Investigation in relation to investigation matters were not approved and were left to be ignored, while the general view that the investigating agency must act efficiently and vigilantly without pressure was accepted.

Conclusion: No interference was warranted with the High Court's order, and the special leave petition did not merit grant of relief.

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