In Brief
The Supreme Court examined whether investigations conducted by a police officer who is also the complainant are automatically vitiated. A bench of five judges held that the Narcotic Drugs and Psychotropic Substances Act, 1985 does not prohibit the informant from being the investigator. The Court found that mere apprehension of bias is insufficient; actual bias or prejudice must be proven and established. Each case must be decided on its individual facts and circumstances, not on universal generalization. The Court overruled Mohan Lal v. State of Punjab, which had held that such investigations are per se vitiated, but preserved the case-by-case approach from earlier decisions like V. Jayapaul and Bhaskar Ramappa Madar."
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