Hasanbhai Valibhai Qureshi v. State of Gujarat, (2004) 5 SCC 347 observed, mere fact of further delay in concluding trial should not stand in way of ‘further investigation’ if it would help Court do real and substantial and effective justice. Rama Chaudhary v. State of Bihar, (2009) 6 SCC 346 held, ‘further investigation’ is continuation of earlier investigation and not a fresh investigation or re-investigation to be started ab initio wiping out earlier investigation altogether.

However, question before this Court is whether Section 173(8) of The Code of Criminal Procedure, 1973 permits ‘further investigation’ once Magistrate has accepted a Final Report under Section 173(2)? There is no bar. It is not necessary, acceptance of Final Report should be reviewed, recalled or quashed.

In aforesaid context, we may only say, “a crime never dies”.  

– Hon’ble Justice J.B. Pardiwala, State v. Hemendhra Reddy, [Special Leave Petition (Criminal) No. 7628-7630 of 2017].