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Sri Basavaraj Shivappa Muttagi vs State Of Karnataka on 16 October, 2021

In Ram Lal Narang v. State (Delhi Admn.) [(1979) 2 SCC 322 : 1979 SCC (Cri) 479 : AIR 1979 SC 1791] it was observed by this Court that further investigation is not altogether ruled out merely because cognisance has been taken by the court. When defective investigation comes to light during course of trial, it may be cured by further investigation, if circumstances so permitted. It would ordinarily be desirable and all the more so in this case, that the police should inform the court and seek formal permission to make further investigation when 236 fresh facts come to light instead of being silent over the matter keeping in view only the need for an early trial since an effective trial for real or actual offences found during course of proper investigation is as much relevant, desirable and necessary as an expeditious disposal of the matter by the courts. In view of the aforesaid position in law, if there is necessity for further investigation, the same can certainly be done as prescribed by law. The mere fact that there may be further delay in concluding the trial should not stand in the way of further investigation if that would help the court in arriving at the truth and do real and substantial as well as effective justice. We make it clear that we have not expressed any final opinion on the merits of the case.
Karnataka High Court Cites 147 - Cited by 2 - Full Document

J. Jayalalitha vs State Represented By Superintendent Of ... on 10 January, 2002

In the interest of independence of the magistracy and the judiciary, in the interest of purity of the administration of criminal justice and in the interest of the comity of various agencies and institutions entrusted with different stages of such administration, in deference to the observations of the Apex Court made in RAM LAL NARANG Vs. STATE (DELHI ADMINISTRATION) reported in 1979 SCC (Cri) 479, and the ratio laid down in J.ALEXANDER Vs. STATE OF KARNATAKA reported in 1996 Crl.L.J. 592 and ARJUNA KUMAR Vs. STATE OF ORISSA reported in 1989 Crl.L.J. 449, whatever the decision, the Designated Court is to take, the same shall be in accordance with the Code of Criminal Procedure and in consequence of the above direction.

J.Jayalalithaa vs State Represented By on 10 January, 2002

In the interest of independence of the magistracy and the judiciary, in the interest of purity of the administration of criminal justice and in the interest of the comity of various agencies and institutions entrusted with different stages of such administration, in deference to the observations of the Apex Court made in RAM LAL NARANG Vs. STATE (DELHI ADMINISTRATION) reported in 1979 SCC (Cri) 479, and the ratio laid down in J.ALEXANDER Vs. STATE OF KARNATAKA reported in 1996 Crl.L.J. 592 and ARJUNA KUMAR Vs. STATE OF ORISSA reported in 1 989 Crl.L.J. 449, whatever the decision, the Designated Court is to take, the same shall be in accordance with the Code of Criminal Procedure and in consequence of the above direction.

Jakir Hussain Kosangi And Others vs State Of Andhra Pradesh, Represented By ... on 4 July, 2017

In Narang case it was, however, observed that it would be appropriate to conduct further investigation with the permission of the court. However, the sweeping power of investigation with the permission of the court. However, the sweeping power of investigation does not warrant subjecting a citizen each time to fresh investigation by the police in respect of the same incident, giving rise to one or more cognizable offences, consequent upon filing of successive FIRs whether before or after filing the final report under Section 173(2) Cr.P.C. It would clearly be beyond the purview of Sections 154 and 156 Cr.P.C., nay, a case of abuse of the statutory power of investigation in a given case. In our view a case of fresh investigation based on the second or successive FIRs, not being a counter-case, filed in connection with the same or connected cognizable offence alleged to have been committed in the course of the same transaction and in respect of which pursuant to the first FIR either investigation is under way or final report under Section 173(2) has been forwarded to the Magistrate, may be a fit case for exercise of power under Section 482 Cr.P.C. or under Articles 226/227 of the Constitution.
Andhra HC (Pre-Telangana) Cites 76 - Cited by 11 - S V Bhatt - Full Document

Anil Singh @ Anil Kumar Singh & Ors vs The State Of Bihar, Through The Chief ... on 31 August, 2018

20. It is worth noting that the Court also dealt with the view expressed in Ram Lal Narang8 and stated thus: (Upkar Singh case9, SCC p. 299, para 22) "22. A perusal of the judgment of this Court in Ram Lal Narang v. State (Delhi Admn.)8 also shows that Patna High Court Cr. WJC No.1226 of 2018 dt.31-08-2018 31 even in cases where a prior complaint is already registered, a counter-complaint is permissible but it goes further and holds that even in cases where a first complaint is registered and investigation initiated, it is possible to file a further complaint by the same complainant based on the material gathered during the course of investigation. Of course, this larger proposition of law laid down in Ram Lal Narang case8 is not necessary to be relied on by us in the present case.
Patna High Court Cites 84 - Cited by 0 - R R Prasad - Full Document

Vikas Gupta vs State Of Punjab on 10 January, 2002

"Power of the police to conduct further investigation, after laying final report, is recognised under Section 173(8) of the Code of Criminal Procedure. Even after the Court took cognizance of any offence on the strength of the police report first submitted, it is open to the police to conduct further investigation. This has been so stated by this Court in Ram Lal Narang v. State (Delhi Admn.), AIR 1979 SC 1791. The only rider provided by the aforesaid decision is that it would be desirable that the police should inform the Court and seek formal permission to make further investigation.
Punjab-Haryana High Court Cites 13 - Cited by 0 - R C Kathuria - Full Document
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