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    <title>2019 (4) TMI 461 - MADRAS HIGH COURT</title>
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    <description>Under the NDPS Act, a request for extension of the investigation period remained valid where the Public Prosecutor filed a report before expiry of the statutory period, even though an earlier application had been moved by the Investigating Officer, because substance prevailed over form and the accused had notice and hearing. The Court also held that default bail under Section 167(2) CrPC could not be claimed while a valid extension request was pending before the 180th day, as the right had not accrued. The Public Prosecutor&#039;s report was found sufficient because it showed investigation progress, further steps needed, and reasons for additional time, so the extension order and refusal of default bail were sustained.</description>
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      <title>2019 (4) TMI 461 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=378017</link>
      <description>Under the NDPS Act, a request for extension of the investigation period remained valid where the Public Prosecutor filed a report before expiry of the statutory period, even though an earlier application had been moved by the Investigating Officer, because substance prevailed over form and the accused had notice and hearing. The Court also held that default bail under Section 167(2) CrPC could not be claimed while a valid extension request was pending before the 180th day, as the right had not accrued. The Public Prosecutor&#039;s report was found sufficient because it showed investigation progress, further steps needed, and reasons for additional time, so the extension order and refusal of default bail were sustained.</description>
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