Bikash Ranjan Rout vs The State Home Department Secretary

The Supreme Court held that the High Court erred in upholding the Magistrate's order for further investigation after the accused was discharged, as per Section 173(8) of the CrPC, which allows further investigation only before the charge is framed. The Court emphasized that once an accused is discharged, the Magistrate loses jurisdiction to direct further investigation. Consequently, the appeal was allowed, and the order for further investigation was set aside, reaffirming the principle that a discharged accused cannot be subjected to further inquiry without proper legal basis.