Supreme Court Says Time-Bound Investigation Should Be Ordered Only in Cases of Undue Delay

The Supreme Court has held that courts should not routinely direct time-bound investigations and must do so only where the record shows undue delay or stagnation.

The Court observed that criminal investigations are often affected by practical constraints such as hostile witnesses, unavailable or unusable documents, and parallel proceedings like bail hearings.

While recognising that the right to a speedy trial includes a prompt and diligent investigation, the Court set aside Allahabad High Court orders that fixed a 90-day investigation timeline and granted arrest protection.

Allowing the State’s appeals, the Court reiterated that supervisory directions must be case-specific and justified.

[State of Uttar Pradesh v. Mohd Arshad Khan]