Vinubhai Haribhai Malaviya v. State of Gujarat
(2019) 17 SCC 1 · Supreme Court of India
A magistrate can order further investigation even after a report is filed, so that the truth-finding process is not frozen too early.
Unit IV · Moot Courts, Observation of Trial, Pre-trial Preparations and Internship
First information, investigation and the magistrate's control
Study aid only. Confirm statute numbers with the current bare Act and the official OU LL.B. (3-YDC) 2024–25 syllabus PDF.
Investigation-observation checklist: FIR contents; sections invoked; arrest memo (D.K. Basu points); seizure panchnama; medical/forensic requests; whether further investigation was sought.
Statute sections
| Act / instrument | Section | Name |
|---|---|---|
| Bharatiya Nagarik Suraksha Sanhita, 2023 | 173 | Information in cognizable cases (compare CrPC 154) |
| Bharatiya Nagarik Suraksha Sanhita, 2023 | 176 | Police officer's power to investigate (compare CrPC 156) |
| Bharatiya Nagarik Suraksha Sanhita, 2023 | 193 | Report of police officer on completion of investigation (compare CrPC 173) |
Landmark cases
Hussainara Khatoon v. State of Bihar
(1980) 1 SCC 81 · Supreme Court of India
Investigation and charge-sheet delay that leaves the accused in jail is a constitutional wrong.