Delay in Police Investigation : Supreme Court Clears the Maze

Delay in Police Investigation : Supreme Court Clears the Maze

It has been recently held in Robert Lalchungnunga Chongthu @ R L Chongthu v. State of Bihar [2025] GCtR 1745 (SC) that if investigation into a particular offence has continued for a period that appears to be unduly long, that too without adequate justification, such as in this case, the accused or the complainant both, shall be at liberty to approach the High Court under Section 528 BNSS/482 of Code of Criminal Procedure, 1973, seeking an update on the investigation or, if the doors of the High Court have been knocked by the accused, quashing. 

If the Court finds or the accused alleges (obviously with proof and reason to substantiate the allegation) that there is a large gap between the first information report and the culminating chargesheet, it is bound to seek an explanation from the investigating agency and satisfy itself to the propriety of the explanation so furnished.