MUKESH SINGH vs STATE (NARCOTIC BRANCH OF DELHI)

The Supreme Court referred the matter regarding the validity of trials conducted by police officers who are also complainants to a larger bench, doubting the correctness of the decision in Mohan Lal v. State of Punjab (2018) 17 SCC 627. The Court held that the principles of fair trial under Article 21 necessitate that the investigation must be conducted impartially, and if the investigator is the complainant, it raises concerns about the fairness of the trial. The decision in Mohan Lal was held to apply prospectively, meaning it governs future cases while prior cases remain subject to their individual facts.