Context: Further Investigation Court Permission
In Paliswamy Veeraraja v. State of Karnataka, 2026, the Supreme Court held that after filing a closure report or chargesheet, further investigation cannot be conducted without prior permission of the concerned Magistrate.
Legal Basis
Section 173(8), Criminal Procedure Code, 1973
- Permits further investigation and filing of a supplementary report after submission of the final report.
Section 193(9), Bharatiya Nagarik Suraksha Sanhita, 2023
- Provides for further investigation and supplementary report after submission of the final report.
Important Point
The provisions are silent on court permission.
However, judicial interpretation has evolved to require prior permission of the Magistrate.
Supreme Court Position
The consistent position has evolved through:
- Vinay Tyagi v. Irshad Ali, 2013
- Rama Chaudhary v. State of Bihar, 2024
- Robert Lalchungnunga Chongthu v. State of Bihar, 2025
- Paliswamy Veeraraja v. State of Karnataka, 2026
Final Position
Further investigation is permissible.
But prior permission of the Magistrate is required before filing a supplementary chargesheet or supplementary report.
Related Terms / PYQ Linkage
Zero First Information Report
Zero FIR can be lodged at any police station irrespective of territorial jurisdiction.
It is later transferred to the competent police station.
Electronic First Information Report
e-FIR enables electronic reporting of cognizable offences for faster access to justice.
