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    <description>A prior Supreme Court ruling limiting the use of concluded-trial evidence for Section 319 proceedings did not bar further investigation on fresh and independent material. The first police report had kept further investigation open, the petitioner was not named in the original challan, and later evidence such as call-detail records and linkage material was collected after the trial. On that basis, the arrest and remand were treated as founded on new material, not as a breach of the earlier directions, and the challenge to the proceedings failed.</description>
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      <description>A prior Supreme Court ruling limiting the use of concluded-trial evidence for Section 319 proceedings did not bar further investigation on fresh and independent material. The first police report had kept further investigation open, the petitioner was not named in the original challan, and later evidence such as call-detail records and linkage material was collected after the trial. On that basis, the arrest and remand were treated as founded on new material, not as a breach of the earlier directions, and the challenge to the proceedings failed.</description>
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