Krishan Lal Gera vs State Of Haryana & Ors on 4 July, 2011
14. It is argued that the decision in Kishan Lal v. State
(supra) was passed before Section 36A of the NDPS Act had
been added by way of an amendment. It is stated that Section
36A of the NDPS Act empowers the Special Court to extend the
time of investigation up to one year on report of the Public
Prosecutor indicating the progress of investigation and specific
reasons for detention of accused.