R.A.H. SIGURAN vs SHANKARE GOWDA @ SHANKARA

The Supreme Court reiterated that an invalid investigation does not automatically nullify the cognizance or trial based on it, as established in H.N. Rishbud v. State of Delhi, AIR 1955 SC 196. The Court held that while the investigation must be conducted by a Special Police Officer under Section 14 of the Act, the trial can proceed unless prejudice is shown. The High Court's quashing of the proceedings was deemed inappropriate as the trial had already commenced without evidence of prejudice from the invalid investigation.