A STUDY ON POWERS AND DUTIES OF INVESTIGATION OFFICER DURING AND AFTER THE INVESTIGATION INTO AN OFFENCE IN INDIA" BY- Law Padho

 This article is written by Kunal Yogesh Nadkarni, a student at Symbiosis Law School, Hyderabad, where he discusses about the  "A STUDY ON POWERS AND DUTIES OF INVESTIGATION OFFICER DURING AND AFTER THE INVESTIGATION INTO AN OFFENCE IN INDIA"

 

TOPIC: A STUDY ON POWERS AND DUTIES OF INVESTIGATION OFFICER DURING AND AFTER THE INVESTIGATION INTO AN OFFENCE IN INDIA.

 

CHAPTER I: INTRODUCTION 

“Nothing matters but the facts. Without them, the science of criminal investigation is nothing more than a guessing game.”

Blake Edwards 

The “Law of the Land” is the elementary functional foundation for the Penal Justice Structure. Humanity, since the dawn of civilization, has emphasized the need for an effective and efficient management of the Penal Justice System, which continues to be the primitive object of mankind aspiration. The very process of a law in a self-governing environment warrants a nature of widespread authorization and dispensation and adherence to the law. Moving forward with the establishment of the truth and circumstances, which include the identity of the said offender and considering due cognizance of all the critical breach of law as and when it happens, is thus considered as a fundamental movement of police enforcement. Such an exercise in the structure of criminal law is duly referred to as an “Investigation”.  Furthermore, any step taken by police authorities or a competent personal authorized by the magistrate towards collection of evidence would fall within the ambit of the word ‘Investigation’.

In adherence to the “Criminal Procedure and Investigations Act, 2016”, ‘An Investigator’ is defined as any police personal involved in the conduct of a criminal investigation. The investigator has a distinct professional role and is tasked with drawing inputs from the crime scene. In adherence to the definition, predominantly, the following steps have been laid down by the “Court of Law” which constitute an investigation: (i) advancing to the crime scene, (ii) the facts and circumstances of the case be ascertained, (iii) determination and taking the suspect into custody, (iv) assembly of evidence and, (v) taking the adequate steps for filing the charge sheet under “Section 173 of Code Of Criminal Procedure, 1973.”

“Section 154 of the Code of Criminal Procedure, 1973” requires primary detailed information regarding the occurrence of any cognizable offence to be recorded in writing, which shall be done by the investigating officer or under his discretion. The first step involved is referred to as the “First Information Report”, the pre-dominant object of which is to set the investigation process in reference to the offence and the Penal law in motion. The FIR is a vital piece of information to form collaboration with the evidence in a criminal trial. The primary duty of an investigation officer is not only to ensure a conviction in the court of law but also bring out the real unvarnished truth.

“Section 161 of Code of Criminal Procedure, 1973” lays emphasis on registration of testimony by the concerned investigation authorities, assembly of evidence in the shape of documents, forensic evidence etc. While, “Section 164 of Code of Criminal Procedure, 1973” provides for recording of a statement or confession before the magistrate. Another primitive duty of the investigation officer is assembly of evidence in the shape of witness statements, documental evidence, etc in order to forming a direct link between the suspected offender and the offence.

“Under Section 173 of Code of Criminal Procedure, 1973”, after the stages of evidence collection have concluded, the investigating authorities must submit before the concerned magistrate the Final Report, which in turn constitutes the assembly of evidence in the presence of the “Investigating officer” and conclusion of the procedure of investigation. The following procedure is followed by the drafting of the charge sheet which contains the elements in relation to the offence, the thorough investigation carried out by the police authorities, the charges framed against the offender, the copy of the FIR, the elements of the case in brief and relevant proof collected in the form of witness statements and documental evidence. Thus, after the investigation has been concluded, it is the underlying responsibility of the investigation officer to prepare the Final Report and the Charge sheet.

The Research Paper explores the pertinent challenges that can potentially arise in the process investigation in adherence to “The Code of Criminal Procedure, 1973”. The Research Paper predominantly focuses on the powers and the duties of an investigation officer during and after the investigation has concluded. The powers and duties of the officer in relation to Section 154(FIR), Section 161 and 164 (Stages of Evidence) and Section 173(Final Report and Charge sheet) will be examined in detail. The Nature, Scope and Significance of the Procedure of Investigation will be emphasized. Furthermore, emphasis will be laid enumerating and   analysing the powers vested in the police authorities by the law of the land to perform the investigation and uphold the spirit and integrity of the principle of Justice.

CHAPTER II: Powers and Duties in adherence to determination of an offence into Cognizable or Non-cognizable.

2.1 Comparative Analysis between Cognizable and Non-Cognizable offence

The Fundamental Criteria for distinction are as follows[1]:

Sr No.	Point of Distinction	Cognizable Offence	Non-Cognizable Offence
1.	Cognizance	The police can take Suo moto cognizance of the crime without the prior approval of the court.	The Police need to take Prior permission of the court.
2.	Warrant	The police have the discretion to take a person in custody without a warrant.	The police must possess a prior warrant before arresting a person.
3.	Embarkment of Investigation	The police can commence investigation on the receipt of information.	The police need prior approval of the concerned Magistrate in form of an order to commence investigation.
4.	Registration of Complaint	A complaint can be filed in form of a First Information Report or a complaint to the concerned Magistrate.	Only a complaint can be filed before the concerned Magistrate.
5.	Nature of Crime	Heinous and Barbaric in nature. For instance, Murder, Rape, Theft.	Not so series in nature. For example, forgery and defamation

 

2.2 Powers of the Investigating Officer in relation to Section 155 of C.r.P.C

“Section 155 of C.r.P.C”[2]lays emphasis on the fact that the Investigating officer is not authorised to investigate in case of “non-cognizable offence without the prior permission of the Magistrate”.[3] Herein, in adherence to Section 155(2),[4] the concerned Magistrate has the discretion to issue directions to the officer to commence investigation in relation to a non-cognizable offence and merely after issue of such orders the officer can exercise the power conferred under the below-mentioned section in relation to Cognizable offence.

In the litigation of “Narendra Pratap Singh v. State of Tripura”,[5] the investigating officer registered the complaint on the fundamental basis of the primary information and embarked investigation without the prior permission of the concerned Magistrate. Herein, the court quashed such investigation on the reasoning that it was outside the jurisdiction of the officer, was ipso facto bad in the eyes of law and contrary to the provisions established by law. The same was reiterated in the cases of “Pradeepa v. State of Karnataka[6] and Nabisab Imansab v. State of Karnataka.” [7] To conclude, it is imperative to have a precise interpretation of the above-mentioned section, taking into consideration the mandatory compliance.

2.3 Powers of the Investigating Officer in relation to Section 156 of C.r.P.C

Section 156 of C.r.P.C,[8] lays emphasis on the power of the concerned Police officer to investigate a Cognizable offence. Herein, an investigating officer on the receipt of suitable details indicating “commission of a Cognizable offence”, shall register an FIR under Section 154 as mentioned above and in adherence to the power conferred in the above-mentioned section must employ investigation of such an offence. [9] In case of a Cognizable offence, the officer has the discretion to investigate without the prior approval of the Magistrate. Furthermore, in the litigation of “Tula Ram v. Kishore Singh” [10], it was briefly stated that the Magistrate in adherence to Section 190 of C.r.P.C. [11] have the power to take cognizance of a particular complaint and employ investigation in relation to the above-mentioned section.

2.4 Powers and Duties Investigating Officer in relation to Section 157 C.r.P.C

Section 157 of C.r.P.C [12], lays emphasis on the procedure to be adhered in case of investigation of Preliminary Inquiry. Herein, in the case of “State of Maharashtra v. Sarandharsingh Chavan”[13], it was held that if there is reasonable intuition in relation to the occurrence of a cognizable offence, it is the fundamental duty of the officer to deliver the report to the concerned Magistrate who in turn can take cognizance of the matter on primary basis of the police report. Elaborating, only in cases wherein a cognizable offence is constituted, a preliminary inquiry can be ordered.

CHAPTER III: Powers and Duties in adherence to “Section 154 of the Code of Criminal Procedure,1973”.

3.1 Fundamental Importance of First Information Report

The F.I.R. is a pivotal piece of information to “set the Criminal Law in motion” and to form corroboration with the evidence in a criminal trial. The Fundamental duty of an investigation officer is not merely to ensure a conviction in the court of law but also bring out the real unvarnished truth. Also, emphasising the mere fact that Section 154 forms the base for further actions in relation to investigation, makes it furthermore imperative to have a precise interpretation of the Section. In the matter of “T.T. Anthony v. State of Kerala”,[14] the Apex Court laid down a series of guidelines which emphasised the importance of F.I.R. The notion of the mandatory registration of F.I.R was reiterated in the cases of “B. Premanand v. Mohan Koikal” [15], “Hiralal Rattanlal v. State of Uttar Pradesh”[16] and “Govindlal Patel v. Agricultural Produce Market Committee” [17].

3.2 Powers and Duties of Investigating Officer

In the milestone litigation of “Lalita Kumari v. Government of Uttar Pradesh”[18], the “Constitutional Bench of the Hon’ble Supreme Court of India” rendered a series of directions taking into consideration the interest of the society at large as well as ensuring a strict and precise enunciation and interpretation of law,[19] it is of substantial and imperative importance that the Police must register a “First Information Report” after receiving adequate information in relation to the commission of a Cognizable offence in adherence to “Section 154 of the Code of Criminal Procedure,1973”.[20] The same was reiterated in the matters of “State of Haryana v. Bhajan Lal” [21]and “Ramesh Kumari v. NCT Delhi” [22]. Furthermore, the bench also laid fundamental emphasis on the notion that, failure on the part of the officer to perform his duty will be subject to intense scrutiny and disciplinary conduct.

Furthermore, taking into consideration the fundamental case of “Maneka Gandhi v. Union of India” [23], in adherence to “Article 21 of the Constitution of India”,[24] it imperatively emphasises laws which are reasonable, and thus it is of substantial importance that a police officer is satisfied that a prime facie case is constituted. In adherence to the Criminal Amendment Act 2013, if the officer has Bona Fide apprehensions in relation to the credibility of the information, then in such a case he can hold a preliminary inquiry as reiterated in the cases of “Selvi v. State of Tamil Nadu” [25]and “Shashikant v. Central Bureau of Investigation”[26]

CHAPTER IV: Importance of the Stages of Evidence in accordance with “Section 161 and 164 of the Code of Criminal Procedure,1973”

4.1 Introduction

The term statement has not been expressly defined under the Act; however, it can be interpreted in form of the action of either affirming or delivering. In terms of the Code, statements are recorded in adherence to the provisions under Sections 161[27] and 162,[28] while the confessions of the accused are recorded in consonance with Section 164. [29]

4.2 Relevancy and Purview of statements in adherence to Section 161 C.r.P.C

Section 161, lays emphasis on the provision for oral examination by the Investigating officer in adherence to a person who is well informed and familiarized with the details of the matter in issue. The fundamental goal of the provision is to accumulate relevant evidence of the commission of crime in form of examination and recording of statements of the material witnesses and to employ the statement recorded in form of admissible evidence in the court of law under Section 162. Herein, under the said provisions a series of guidelines have been implemented: Firstly, an officer has the discretion to orally examine a witness under the provisions of the act, Secondly, the witness must duly answer all the questions put forward and, Thirdly, the officer is “duty bound” to record such statements in writing as well.

In the litigation of “Appabhai v. State of Gujrat”[30], it was observed by the Apex Court that a situation wherein police are not able to produce witnesses in the court of law, raises light on the mere fact that even Educated citizens are basically inconsiderate and are hesitant to approach the court of law, unless absolutely necessary. Furthermore, in adherence to the statements recorded under Section 162 cannot be used for corroboration with other forms of evidence or for undertaking of statement in the court of law. It can only be used for contradicting the statements of the prosecution witnesses. For instance, as mentioned in the above-mentioned case, if a witness makes a testimony in the court of law that a fundamental fact exists without revealing the same before the police, then in such a case the statement recorded under section 162 could be employed. Also, in the case of “Ganesh Gulve v. State of Maharashtra” [31],  it was held that in view of appreciation of evidence, it is the prominent duty of the court to take into consideration the nature and the environment surrounding the crime committed in relation to the magnitude of the understanding of the crime. Furthermore, in the case of Appabhai as mentioned above, it was held that there are bound to be minor discrepancies in the statements.

4.3 Evidentiary Value of Statements under Section 161 C.r.P.C

It is not mandatory to for a statement recorded under Section 161 to be self-attested by the witness. Herein, in adherence to Section 162, the notion of self-attesting a statement is barred and amounts to contradictions of the provisions established by law and can lead to diminishing the value of the statements in the court of law. In the case of “State of Uttar Pradesh v. MK Anthony”, [32] it was held that a statement produced in Court in adherence to Section 162 shall not be rendered inadmissible merely on the fact that it was self-attested by the witness. The same was reiterated in the case of “State of Rajasthan v. Teja Ram”.[33] Furthermore, it is a well-established principle in law that a delay in recording the statement will be considered credible provided the investigating officer provides a reasonable explanation for the contentment of the court.[34]

4.4 Relevancy and Purview of statements in adherence to Section 164 C.r.P.C

The term confession has not been expressly defined in the Indian Evidence Act, 1872, however it can interpret as a certified statement made by the accused in admission of his guilt. To fulfil the test of confession, either it should be made admitting the guilty in the offence or acceptance of the facts of the case which constitute an offence, if it doesn’t fulfil the following it will be not be considered a confession. Such a statement will be merely termed as an admission. Furthermore, admission of guilt violates, Firstly, “The Right to Privacy guaranteed under Article 21 of the Constitution” and secondly, “The Right Against Self-Incrimination guaranteed under Article 20(3) of the Constitution”.[35], which lays emphasis on the fact that a person cannot be compelled to be a witness against himself.

In the case of “Pakala Narayana Swami v. Emperor” [36], the Apex Court rendered a precise interpretation of Confession, wherein, even the acceptance of a conclusive incriminating fact shall not in itself be considered a confession. For instance, an admission that the accused is the owner of the rifle which caused the death of the victim.

4.5 Power and Duties to record confession statements

In adherence to Section 164, the Judicial or Metropolitan Magistrate have the discretion to record confessions and statements in course of as well as post the commencement of trial. Fundamental emphasis is laid on the fact that the accused is not bound to make a confession, however, every confession recorded in the presence of magistrate shall be considered as admissible evidence in the court of law. In the case of “Kartar Singh v. State of Punjab”,[37] it was rendered that in relation to Section 164(2) and Rule 32 of the Criminal Rules of Practise, it is the imperative duty of the investigating officer to produce the accused before the concerned Magistrate, wherein, the Magistrate should briefly explain the rights available to the accused in relation to recording a confession as well as the substantial fact that such a confession made will be employed as evidence against him.

The fundamental purpose of recording a statement under Section 164 in addition to Section 162: (1) To prevent witnesses from changing their statements in the fore coming future and (2) to provide immunity to the approval recording the statement. Thus, the presence of the charge of Perjury diminishes the probability of the change in statement. Furthermore, since in adherence to Section 162, the police have the discretion to record statements but such statements aren’t administered under oath thus making it inadmissible in the court of law. While in adherence to Section 164, the statements are recorded under oath which makes it admissible as well as diminishes the chances of hostility. [38]

In relation to the evidentiary value of Section 164, the statements recorded cannot be considered as substantive evidence. The statement cannot be the sole fundamental ground for conviction. It can be used as a corroborative form of evidence. It is at the discretion of the court to examine whether such a statement was recorded without any coercion as well as ensure that the procedural requirements under sub clause (2) and (4) are outrightly adhered.  [39]

CHAPTER V: The Principal Duty of the Investigation Officer in adherence to “Section 173 of the Code of Criminal Procedure,1973”

5.1 Duty to conduct Fair Investigation

In adherence to Article 21 of the Constitution of India, [40] the judiciary interprets the article with a diverse amplitude as it comprises of the right to fair trial which in turn lays emphasis on the duty of the investigating officer to conduct an impartial trial. “The Law Commission of India”, in its 41^st Report paid diligence on the right to fair trial in consonance with the principles of natural justice and audi alterum partem.[41] In the matter of “Dhanaj Singh v. State of Punjab”, [42], it was rendered that, in view of the sanctity of the criminal justice system and the common welfare of the public at large, it is imperative to promote and uphold the right to fair trial. The same was reiterated in the matter of “Zahira Habibullah Sheikh v. State of Gujrat”[43] famously termed as the “Best Bakery case”. Thus, in respect of the right of fair trial, it is the predominant duty of the Investigating officer to employ a detailed examination of the evidence, in order to constitute whether prime-facie charges are made out. Furthermore, if no charges ae constituted then the closure report filed under Section 169 shall be considered as the final report under Section 173.

5.2 Duty to prepare Final Report and Charge sheet

The expression “Report” denotes collaboration and communication of notable information in form of an official documented representation of the facts of the case. Section 173 C.r.P.C[44] provides for submission of the Police Report to the concerned Magistrate. The Report generally provides a brief overview of the investigation initiated in accordance with Section 155 or 156 as mentioned above, for an official proposal for action. Such a report can also be referred as the Charge sheet. Basically, charge sheet is prepared fundamentally on the basis of the preliminary investigation and is subsequently followed by the final report. Thus, in adherence to Section 173 it is the imperative duty of the investigation officer to fundamentally present all the relevant facts and material evidences, in form of an official well-documented report to the concerned Magistrate for further course of action.  Emphasizing the fundamental importance of the Police report, the report contains a brief summary of the investigation undertaken as well as the material evidences in form of witness statements etc. which forms a strong base for ensuring prosecution of the accused in the court of law. Thus, it is of paramount importance that the investigation officer prepares a conclusive report to the Magistrate. Furthermore, if, fundamentally, on the basis of the police report filed, it is concluded that the evidences are conclusive to constitute charges, then in such a case the Final report is prepared which is referred to as the Charge sheet, which is a comprehensive summary of the charges levied against the accused on the basis of the facts and material evidences.[45]

5.3 Right to conduct Further investigation

On the fundamental basis of the direction of the “Law Commission of India” (41^st Report), section 173(8) was inculcated in the Code.[46] Section 173(8) C.r.P.C. provides for further investigation. In the case of “Divakar Singh v. Ramamurthi Naidu”, [47] it was rendered that, although after the submission of the final report of investigation under Section 173, the police have no discretion to further investigation, however, emphasis is laid on the notion that the quota of investigations into a particular crime is not restricted by law and further investigation can be constituted on the basis of fresh information in relation to the subject-matter. The HC in the case of “State v. Mehar Singh”, [48] was of the view that, the discretion of the police is over once the charge sheet if filed and the magistrate takes cognizance. However, the SC in the case of “H.N. Rishbud v. State of Delhi”, [49] held that, it is the up to the discretion of the Magistrate to suspend cognizance and direct the police to conduct further investigation. 

CHAPTER VI: CONCLUSION

Taking into consideration, determination of Offence into Cognizable and Non- Cognizable, Section 155, mandates the prior approval of the Magistrate before the investigating officer can take cognizance of the case. While, Section 156, gives discretion to the Investigating officer to take cognizance of the case without the prior approval. Herein, it is the fundamental duty of the investigation officer to determine which classification the case will fall into on the basis of the primary information received.

Emphasising the importance of the “First Information Report”, it is a vital document which can be not only used for “corroboration” but it also forms the base for the future course of investigation. Thus, one of the most predominant duty of the investigation officer is the registration of FIR in adherence to Section 154, on the fundamental basis of material details received in case of a cognizable offence.

Evidence is considered as the principal piece of the puzzle as it forms a direct connection between the accused and the commission of crime. In adherence to Section 161, it is the imperative duty of the investigating officer to accumulate relevant evidence of the commission of crime in form of examination and recording of statements of the material witnesses and to employ the same in form of admissible evidence in the court of law under Section 162. Furthermore, in adherence to Section 164, the officer has the power to record the confession statement of the accused in presence of the concerned Magistrate.

Fundamental Rights form the base of the Indian Constitution. In adherence to Art 21, the right to fair trial is given substantial importance. Thus, it’s the duty of the officer to employ a detailed examination of the evidence, in order to constitute whether prime-facie charges are made out. In adherence to Section 173 it is the imperative duty of the investigation officer to fundamentally present all the relevant facts and material evidences, in form of an official well-documented report (Chargesheet) to the concerned Magistrate for further course of action. Also, in respect to Section 173(8) the officer has the right to conduct further investigation on the basis of fresh material information.

The unprecedented increase in the crime rate has developed into a serious issue for the administrators as well as the “Criminal justice system” and also for the functioning of the social organizations and safety of the society at large, with the nation on its path to be termed as the prime-hub for crime. Thus, it’s the imperative duty of the Investigating agencies to uphold the sanctity of justice.

Author- Kunal Yogesh Nadkarni,

Symbiosis Law School, Hyderabad.

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[1] R. Deb, Police Investigation: A Review, Journal of the Indian Law Institute, Vol.39 No.2/4, December 1996, Pg. 260-271.

[2] Section 155 of the Code of Criminal Procedure, 1973: Information as to non- cognizable cases and investigation of such cases.

[3] Syed Shabeer v. State of Karnataka, September 8, 2017.

[4] Section 155 of the Code of Criminal Procedure, 1973: No police officer shall investigate a non- cognizable case without the order of a Magistrate having power to try such case or commit the case for trial.

[5] Narendra Pratap Singh v. State of Tripura, July 8, 2014.

[6] Pradeepa v. State of Karnataka, January 25, 2019.

[7] Nabisab Iman sab v. State of Karnataka, December 18, 2018.

[8] Section 156 of the Code of Criminal Procedure,1973: Police officer' s power to investigate cognizable case.

[9] Rohit Gupta, Scope of Inquiry by the Police at the time of Registration of FIR, February 27, 2014.

[10] Tula Ram v. Kishore Singh, October 5, 1977.

[11] Section 190 of the Code of Criminal Procedure,1973: Cognizance of offences by Magistrates.

[12] Section 157 of the Code of Criminal Procedure,1973: Procedure for investigation preliminary inquiry.

[13] State of Maharashtra v. Sarandharsingh Chavan, December 14, 2010.

[14] T.T. Anthony v. State of Kerala, 2001 6 SCC 181.

[15] B. Premanand v. Mohan Koikal, 2011 4 SCC 266.

[16] Hiralal Rattanlal v. State of Uttar Pradesh, 1973 1 SCC 216.

[17] Govindlal Patel v. Agricultural Produce Market Committee, 1975 2 SCC 482.

[18] Lalita Kumari v. Government of Uttar Pradesh, November 12, 2013.

[19] R. Deb, Police Investigation: A Review, Journal of the Indian Law Institute, Vol.39 No.2/4, December 1996, Pg. 260-271.

[20] Section 154 of the Code of Criminal Procedure,1973: Information in Cognizable cases.

[21] State of Haryana v. Bhajan Lal, 1992 SCC 335.

[22] Ramesh Kumari v. NCT Delhi, 2006 2 SCC 677.

[23] Maneka Gandhi v. Union of India, 1978 1 SCC 248.

[24] Article 21 of the Constitution of India: Protection of life and personal liberty.

[25] Sseelvi v. State of Tamil Nadu, 1981 SCC 43.

[26] Shashikant v. Central Bureau of Investigation, 2007 1 SCC 630.

[27] Section 161 of the Code of Criminal Procedure, 1973: Examination of witnesses by police.

[28] Section 162 of the Code of Criminal Procedure, 1973: Statements to police not to be signed: Use of statements in evidence.

[29] Section 164 of the Code of Criminal Procedure, 1973: Recording of confessions and statements.

[30] Appabhai v. State of Gujrat, A.I.R. 1988 SC 696.

[31] Ganesh Gulve v. State of Maharashtra, August 21, 2002.

[32] State of Uttar Pradesh v. MK Anthony, 1985 SCC Crl 105.

[33] State of Rajasthan v. Teja Ram, A.I.R. 1999 SC 1776.

[34] Ganesh Bhagvan v. State of Maharashtra, 2005 DMC 445.

[35] The Role of DNA in Criminal Investigation: Admissibility in Indian Legal System and Future Perspectives, International Journal of Humanities and Social Science Invention, Vol 2 Issue 7, pp 15-21.

[36] Pakala Narayana Swami v. Emperor, A.I.R. 1939 P.C. 47.

[37] Kartar Singh v. State of Punjab, 1994 CrLJ 3139.

[38] Sobha Kumari, Scope and Relevance of Statements recorded under Section 161 and 164 of Code of Criminal Procedure,1973.

[39] Paramananda v. State of Assam, 2004 2 Crl 657.

[40] Article 21 of the Constitution of India: Protection of life and personal liberty.

[41] Mukund Sarda, Police Investigation and Closure Report.

[42] Dhanraj Singh v. State of Punjab, A.I.R. 2004 SC 524.

[43] Zahira Habibullah Sheikh v. State of Gujrat, A.I.R. 2004 SC 311.      

[44] Section 173 of the Code of Criminal Procedure, 1973: Report of police officer on completion of investigation.

[45] Carla Porte, Investigation and Prosecution of Large-scale Crimes at the International Level, Journal of International Criminal Justice, 4 (2006), 539-558.

[46] Nageshwara Rao & J. Manthani, Different Aspects of Section 173(8) C.r.P.C.

[47] Divakar Singh v. Ramamurthi Naidu, A.I.R. 1919 Mad 751.

[48] State v. Mehar Singh, 1974 Crl LJ 970.

[49] H.N. Rishbud v. State of Delhi, A.I.R. 1955 SC 196.