S.M. DATTA vs STATE OF GUJARAT

The Supreme Court reiterated the principle established in Khwaja Nazir Ahmed's case, emphasizing that courts should not interfere with police investigations into cognizable offences unless no offence is disclosed. The Court held that the police have the statutory right to investigate without judicial authority, and this right should not be undermined by the judiciary. The judgment clarified that while individual liberty is paramount, it must be balanced with the need for effective law enforcement when a cognizable offence is disclosed in an FIR.