STATE OF BIHAR AND ANR. vs J.A.C. SALDANHA AND ORS.

The Supreme Court held that under Section 172(2) of the Criminal Procedure Code, 1973, the State Government is not precluded from directing further investigation in a case where a final report has been submitted but no order has been passed by the court. The Court clarified that the Inspector General of Police Vigilance qualifies as a 'superior' officer under Section 36 of the Code, thereby allowing for further investigation. The judgment emphasizes the court's limited role in interfering during the investigation stage, affirming the powers of the police to conduct further inquiries as necessary.