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    <title>2022 (2) TMI 566 - DELHI HIGH COURT</title>
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    <description>Delay in investigation does not, by itself, justify quashing an FIR under inherent powers where the case concerns alleged manipulation of letters of credit and export-related offences. The court applied the settled position that there is no rigid outer time limit for completing an investigation; delay must be assessed in the factual context, with Article 21 rights balanced against the need for a fair and effective inquiry, especially in serious cross-border economic offences. As the record involved foreign documents, letters rogatory and requests to overseas authorities, and no substantial prejudice was shown, the investigation was treated as still at a crucial stage. The petition to quash was therefore not allowed.</description>
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      <title>2022 (2) TMI 566 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=418315</link>
      <description>Delay in investigation does not, by itself, justify quashing an FIR under inherent powers where the case concerns alleged manipulation of letters of credit and export-related offences. The court applied the settled position that there is no rigid outer time limit for completing an investigation; delay must be assessed in the factual context, with Article 21 rights balanced against the need for a fair and effective inquiry, especially in serious cross-border economic offences. As the record involved foreign documents, letters rogatory and requests to overseas authorities, and no substantial prejudice was shown, the investigation was treated as still at a crucial stage. The petition to quash was therefore not allowed.</description>
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