In Brief
The Supreme Court held that a Magistrate retains the power to order further investigation after a charge-sheet is filed and cognizance is taken, provided charges have not yet been framed (i.e., the trial has not commenced). This power flows from Sections 156(3) and 173(8) of the CrPC and is anchored in Article 21's mandate of fair investigation. The Court overruled recent judgments that had restricted the Magistrate's post-cognizance powers, clarifying that investigation continues until charges are framed, not merely upon cognizance. On the facts, the Court set aside the order for further investigation in the original FIR as the alleged facts constituted a separate case, but directed the police to register a new FIR based on the Commissioner of Revenue's findings and investigate it independently within three months.
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