The Supreme Court has expressed serious concern over a criminal investigation in Gujarat that has remained unresolved for nearly two decades. Calling attention to the constitutional importance of timely investigations, the Court directed the Gujarat Police to complete the pending probe within six weeks and place a proper report before the trial court.
The order came in an appeal filed by the legal heirs of the original complainant, who had been seeking action in an alleged forgery and property fraud matter dating back to 2007.
Background of the Case
The dispute concerns a parcel of land in Bhiloda village of Gujarat. According to the complaint, the property belonged exclusively to the complainant. It was alleged that while he was away on a Haj pilgrimage in 2002, certain persons prepared forged documents, including a partition deed and a sale deed, allegedly using fabricated signatures. These documents were later used to secure entries in revenue records.
Over the years, the complainant repeatedly approached courts seeking completion of the investigation. Despite several directions from the Judicial Magistrate and the Gujarat High Court, no final outcome emerged.
A forensic examination conducted during the investigation reportedly indicated that the signatures on the disputed documents were not authored by the complainant. Yet, even after the report was received, the investigation remained pending.
Justice Sanjay Karol, writing for the Bench, opened the order with the observation that, “Justice delayed is justice denied.” The Court noted that almost nineteen years had passed since the complaint was lodged, but the investigation had not reached any meaningful conclusion.
The Bench observed that the complainant had “run from pillar to post” seeking filing of a charge sheet, but without success. It held that constitutional courts should not remain passive when such prolonged investigations are brought to their notice.
The Court further emphasized that the right to a speedy investigation and trial forms an essential part of the right to life and personal liberty guaranteed under Article 21 of the Constitution.
The State informed the Court that original investigation records and materials had been misplaced while being transmitted to the trial court. According to the State, disciplinary proceedings were initiated against the concerned officer. It was also argued that the loss of records and inability to trace certain witnesses prevented the investigation from being completed.
However, the Bench found the explanation unsatisfactory. It noted that nearly a decade had passed even after re-investigation was ordered and questioned why the investigating agency had neither completed the probe nor filed an appropriate closure report before the Magistrate.
Allowing the appeal, the Supreme Court directed the State of Gujarat and Bhiloda Police Station to conclude the investigation within six weeks and submit an appropriate report before the Judicial Magistrate along with all available investigative material.
The Court also directed the State to file an affidavit detailing the action taken against the officer responsible for the loss of records, explaining why the Magistrate was not informed about difficulties in reconstructing the case records, and confirming compliance with the Court's directions.
The matter has been listed for further hearing on July 14, 2026.
Case Details
Case Title: Sahil Abdulsattar Mansuri & Ors. v. Safimahamad Fafirbhai Mansuri & Ors.
Case Number: Criminal Appeal arising out of SLP (Crl.) No. 17479 of 2025
Judges: Justice Sanjay Karol and Justice Augustine George Masih
Decision Date: June 4, 2026
