Jharkhand High Court Reaffirms Right to Speedy Investigation, Directs Completion of Probe Within Three Months
W. P. (Cr.) No. 91 of 2025
By Navya Tiwari
In Bijay Kumar Prajapati v. State of Jharkhand & Ors. (10 March 2026), the Jharkhand High Court disposed of a criminal writ petition seeking expeditious investigation, reiterating that the right to a speedy investigation is a constitutional mandate.
The case arose from Katkamdag P.S. Case No. 66 of 2022, registered under Sections 406, 420, and 120-B of the IPC. The petitioner, Bijay Kumar Prajapati, alleged that the accused had fraudulently sold him a parcel of land through misrepresentation, despite having previously sold the same property to other purchasers.
The petitioner contended that, despite the lapse of over three years, the investigation remained incomplete, with no meaningful progress allegedly due to collusion between the investigating officer and the accused. In response, the State submitted that complications had arisen as two accused had died during the pendency of the case, while another was a juvenile at the time of the alleged offence.
Justice Gautam Kumar Choudhary observed that such circumstances do not justify indefinite delay in investigation. Emphasizing that speedy investigation, enquiry, and trial are integral to constitutional guarantees, the Court held that the police cannot keep an investigation pending without sufficient cause.
Accordingly, the Court directed the Officer-in-Charge of Katkamdag Police Station to conclude the investigation within three months and disposed of the writ petition.
