Investigating Officer Can't Keep Probe Pending But Court Can't Give Direction To File Chargesheet: Madhya Pradesh High Court

The Madhya Pradesh High Court considered judicial supervisory powers over police investigation and the filing of a chargesheet. The Court clarified two strands: while an investigating officer cannot indefinitely keep an investigation pending without moving toward finality, a court ordinarily cannot direct an investigating agency to file a chargesheet — that operational decision falls within the executive's investigative domain. The ruling explains the boundary between judicial oversight (to prevent mala fide or lax investigation) and the impermissible encroachment upon police discretion to conclude investigations and determine whether evidence warrants prosecution. The High Court directed appropriate steps to ensure timely completion of probe and, where necessary, supervisory intervention, but stopped short of ordering the filing of a chargesheet. The decision underscores constitutional separation of powers, highlights safeguards against investigative inertia, and instructs lower courts on the limited but necessary supervisory jurisdiction to ensure investigations progress properly without judicially micromanaging prosecutorial decisions.