The Supreme Court held that timelines imposed by High Courts to conclude investigations are the exception rather than the norm. It held that Courts must respect the practical realities of investigations and should only impose deadlines in situations where inaction would lead to adverse consequences.
In this case, three individuals approached the Allahabad High Court under Article 226 seeking to quash accusations of forging documents and filing false affidavits to procure arms licenses under the Arms Act, 1959, and the Indian Penal Code, 1860. Relying on Shobhit Nehra v State of Uttar Pradesh (2024), the Allahabad High Court directed investigative agencies to conclude the probe within 90 days and granted the accused protection from arrest until the court took cognisance. The State appealed, arguing that the timeline was unjustified, risked prejudicing a serious criminal investigation and ignored the distinct factual context of Shobhit Nehra.
The Supreme Court set aside the High Court’s order. It noted that Shobhit Nehra arose from a family dispute, unlike the present case involving allegations of serious criminal conduct. The Court held that directions for time-bound investigation must not be issued routinely or as a matter of course. It clarified that relying on judicial precedent is not a mechanical exercise; it must reflect an application of mind to the specific facts of the case.
State of Uttar Pradesh v Mohd. Arshad Khan
19 December 2025
Citation: 2025 INSC 1480 | 2025 SCO.LR 12(5)[23]
Bench: Justices Sanjay Karol and N.K. Singh
Case Comment
Held, we again reiterate the law laid down by this Court in Habib Abdullah Jeelani [State of Telangana v. Habib Abdullah Jeelani, (2017) 2 SCC 779 : (2017) 2 SCC (Cri) 142] and we direct all the High Courts to scrupulously follow the law laid down by this Court in Habib Abdullah Jeelani [State of Telangana v. Habib Abdullah Jeelani, (2017) 2 SCC 779 : (2017) 2 SCC (Cri) 142] and the law laid down by this Court in the present case, which otherwise the High Courts are bound to follow. We caution the High Courts again against passing such orders of not to arrest or “no coercive steps to be taken” till the investigation is completed and the final report is filed, while not entertaining quashing petitions under Section 482CrPC and/or Article 226 of the Constitution of India.”
(emphasis supplied)
The text of the order in no way provides or attempts to provide, as in Shobhit Nehra (supra), any justification for granting protection from arrest despite the position of law laid down in Neeharika (supra). Without going further into the issue, we set aside the condition
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Key words/phrases: Time bound investigations—Protection from arrest—Section 482 of Criminal Procedure Code, 1973—Article 226 of the Constitution of India, 1950—Time bound investigation in rare instances—not a mechanical exercise—application of mind—High Court order set aside.
Read the Judgement here.