In Brief
The Supreme Court clarified the procedure for a Magistrate when both an initial charge sheet (under Section 173(2) CrPC) and a supplementary report recommending closure (under Section 173(8)) are filed. The Court held that a Magistrate must consider both reports conjointly and apply their cumulative effect to determine whether grounds exist to presume the accused committed an offence. The Magistrate's supervisory power to oversee investigation does not cease upon cognizance but continues until charges are framed, in accordance with Article 21's requirement of fair investigation. The case was remitted to the Magistrate to reconsider both reports together in light of Supreme Court precedent.
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