STATE OF BIHAR vs LALU SINGH

The Supreme Court addressed the issue of whether an Inspector of the Criminal Investigation Department (C.I.D.) has the authority to file a charge-sheet under Section 173(2) of the Code of Criminal Procedure (CrPC). The Court held that while higher police officials have supervisory powers under Section 36 CrPC, the final authority to file a charge-sheet rests solely with the officer-in-charge of the police station. The Court dismissed the High Court's observations that limited the filing authority, affirming the validity of the charge-sheet submitted by the C.I.D. Inspector.