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    <title>2017 (12) TMI 1818 - MADHYA PRADESH HIGH COURT</title>
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    <description>A police report under Section 173(2) CrPC may still be valid if further investigation is stated to be continuing, provided the material already placed is sufficient for cognizance. However, where the report itself shows that investigation into the substratum of the offence remains incomplete and is filed at the expiry of the statutory period to defeat the accused&#039;s right to bail, it cannot be treated as a completed final report. On the stated facts, the charge-sheet recorded that further investigation was still in progress, including on the accused&#039;s role in the alleged larger conspiracy, so it was not treated as a completed police report for purposes of Section 167(2) CrPC and default bail followed.</description>
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