In a recent ruling, the Supreme Court clarified that directing further investigation is legally permissible even after the filing of a chargesheet and the commencement of trial, but it must be approached with caution.

The Court emphasized that the central aim of any further investigation is to uncover the truth and ensure justice is served.

This judgment stemmed from the case of Rampal Gautam & Ors. v. The State, where the appellants challenged the Karnataka High Court’s order directing further investigation into cruelty charges.

Citing the landmark Hasanbhai Valibhai Qureshi v. State of Gujarat (2004), the Court reaffirmed that the primary goal of any investigation is to "arrive at the truth and to do substantial justice."

This principle remains valid even after the trial has begun and the chargesheet has been submitted.

However, the Court made it clear that before ordering further investigation, the relevant authority must carefully review the material on record and determine whether such an investigation is warranted.

The case involved a complainant who accused her husband of cruelty. Initially, her allegations against her in-laws were vague and made much later. In her original deposition, the complainant did not mention any accusations against her father-in-law, mother-in-law, or other family members. However, years after the chargesheet was filed, she applied under Section 173(8) of the Criminal Procedure Code for a fresh investigation concerning her in-laws.

The High Court allowed this request, ordering a new investigation. However, the Supreme Court, comprising Justice Vikram Nath, Justice Sanjay Karol, and Justice Sandeep Mehta, criticized this decision, stating that the High Court had erred by directing a fresh investigation, disregarding the fact that the application under Section 173(8) CrPC was significantly delayed.

The Court also pointed out that even in subsequent depositions, the complainant’s allegations were vague, and there was no substantial evidence linking the appellants to the alleged cruelty. The appellants, who were living separately from the complainant and her husband, were not implicated by any credible evidence. The Court further highlighted that the complainant had other legal remedies, such as filing a petition under Section 319 CrPC to summon other family members if necessary.

While quashing the High Court's order, the Supreme Court emphasized that the complainant had ample opportunity to raise her grievances during the trial. At such a delayed stage, there was no valid reason for initiating a fresh investigation. The judgment also clarified that the complainant could pursue alternative legal remedies, including requesting further examination under Section 311 CrPC or moving forward with a Section 319 CrPC application.

The Court concluded by reiterating that the complainant could have included her grievances in her examination-in-chief and requested that the trial court summon the remaining family members under Section 319 CrPC.

Ultimately, the Supreme Court quashed the High Court’s order, finding no legal basis for the direction to conduct further investigation. It also allowed the appeal, affirming that the complainant could explore other legal avenues to address her grievances.

In a related appeal involving the complainant’s husband, the Court dismissed the case, allowing him to present his defense before the trial court, as the trial against him had already commenced.