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Supreme Court of India 2019-05-07 allowed

STATE REP BY INSPECTOR OF POLICE CENTRAL BUREAU OF INVESTIGATION vs M SUBRAHMANYAM

Bench: 2 — Arun Mishra, Navin Sinha

In Brief

The Supreme Court allowed an appeal by the Central Bureau of Investigation seeking to produce an authorization order for investigation after the charge-sheet had been filed. The respondent, an Income Tax Officer, was accused of possessing disproportionate assets. The High Court had rejected the application, treating an earlier rejection as res judicata. The Court held that omission to file documents with the charge-sheet is a procedural lapse only. The word 'shall' in Section 173(5), Cr.P.C. is directory, not mandatory, allowing late production if the court permits. Substantive justice in corruption cases must prevail over procedural technicalities. However, the Court noted unexplained delays warranted administrative inquiry into potential deliberate omission.

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Criminal Procedure Corruption Evidence Procedural Law Prevention of Corruption Act Central Bureau of Investigation

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