The Allahabad High Court has raised serious concerns over prolonged delays in police investigations across Uttar Pradesh, observing that investigating officers have shown considerable inaction in completing investigations. The Court has directed the Additional Chief Secretary (Home), Uttar Pradesh, to submit a personal affidavit explaining how such delays can be addressed.
A Division Bench of Justice Abdul Moin and Justice Pramod Kumar Srivastava passed the order while hearing a petition seeking the transfer of a murder case investigation to an independent agency.
Background
The matter arose from FIR No. 309 of 2024, registered on November 24, 2024, at Jaisinghpur Police Station in Sultanpur district. The police had submitted a chargesheet on April 21, 2025. However, the concerned court, through its order dated February 21, 2026, directed further investigation after finding the initial investigation prima facie unbelievable and unnatural.
The petitioner subsequently approached the High Court, alleging that no further investigation report had been submitted despite the passage of several months. The State informed the Bench that further investigation was still underway.
Examining Section 193 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, the Bench observed that although no fixed completion period is prescribed for most investigations, the law requires every investigation to be completed without unnecessary delay.
The Court emphasised the statutory obligation to inform complainants or victims about investigation progress within 90 days.
The Bench observed:
"The intention of the legislature was that the investigation should not keep hanging fire and the complainant made to run from pillar to post without any information also being given to him with regard to the progress of the investigation which is being conducted by the Investigating Officer."
Expressing concern over recurring complaints, the Court further remarked:
"Considering the various matters which are coming to the Court and which repeatedly pertain to the long delay in investigation, it is high time that the higher authorities should step in and frame modalities pertaining to the time frame in which an endeavour should be made to complete the investigation, including punitive action to be taken against the Investigating Officers who do not complete the investigation within a specified time."
The High Court directed the Additional Chief Secretary (Home) to file a personal affidavit within three weeks, explaining whether a time frame could be fixed for completing investigations and what measures could address prolonged delays.
The affidavit must also disclose how many complainants or victims in FIRs registered in Sultanpur district had been informed about investigation progress.
The matter has been listed for December 8, 2026. If the affidavit is not filed, the Additional Chief Secretary (Home) must appear personally with the relevant records.
Case Details
Case Title: Deepak Kumar v. State of U.P. Through Principal Secretary, Home, Lucknow and Others
Case Number: Criminal Misc. Writ Petition No. 10849 of 2026
Judges: Justice Abdul Moin and Justice Pramod Kumar Srivastava
Decision Date: November 3, 2026
