The Supreme Court on Thursday (November 20) held that trial courts do not become functus officio after permitting further investigation and are obligated to seek explanations from investigating agencies for significant delay in filing supplementary charge sheets.

A bench of Justices Sanjay Karol and N Kotiswar Singh quashed the criminal proceedings against an IAS officer against whom further investigation had remained pending for 11 years, ruling that such unexplained and inordinate delay is sufficient to vitiate the entire prosecution.

Holding that inordinate delay in completing the investigation can be a ground to quash the proceedings, the Court observed, "The accused cannot be made to suffer endlessly with this threat of continuing investigation and eventual trial proceedings bear

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