NIRMAL KANTI ROY vs STATE OF WEST BENGAL

The Supreme Court referred the interpretation of Section 167(5) of the Code of Criminal Procedure, as amended by the West Bengal Act 24 of 1988, to a larger bench due to conflicting judgments in State of West Bengal vs. Falguni Dutta and Durgesh Chandra Shah. The court highlighted that Section 167(5) mandates the discharge of an accused if the investigation is not concluded within specified timeframes, unless special reasons are provided. The outcome of the appeal is pending further clarification from the larger bench.