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Judgment
8.There is undoubted need for a mechanism to take remedial steps if there is undue delay in investigation. Section 57 Cr.P.C. puts a bar o
detention by a police officer beyond  24 hours excepting time necessary for the journey from the place of arrest to the Magistrate’s court.Â
Section 167(1) Cr.P.C. provides that where investigation cannot be completed within 24 hours, the accused has to be produced before the Magistrate
and further detention of the accused has to be authorized by the Magistrate. It is well established that authorization for such detention has to be
given having regard to the progress in investigation. Even a Magistrate cannot authorise detention in police custody beyond 15 days. After judicia
custody for more than 90 days in serious cases stipulated therein and 60 days in other cases, there is a provision for mandatory default bai
requirement if there is delay in investigation beyond the said period. In summons case, if investigation is not concluded within six months, the same
has to be stopped unless continuation is found necessary .  However, there is no express outer limit for investigation in other cases but delay in
investigation may affect reasonableness of procedure specially when a person is in custody and is unable to furnish bail. Hence the need to lay
down timelines for completing investigation with a view to give effect to the mandate of Article 21 of the Constitution. This aspect has also bee
discussed in the Law Commission’s Report including the 14th report (1958) and 154th Report (1996) as noticed by this Court .