Legal Analysis: Sahil Abdulsattar Mansuri and Others v. Safimahamad Fafirbhai Mansuri and Others

Citation: 2026 INSC 626

Court: Supreme Court of India

Bench: A Division Bench comprising Justice Sanjay Karol & Justice Augustine George Masih

Date of Decision: June 4, 2026

Nature of Judgment: Criminal Appeal arising out of SLP (Crl.) No. 17479 of 2025 against the judgment of the High Court of Gujarat at Ahmedabad dated 26th June 2025 in Special Criminal Application (Direction) No. 2029 of 2024.

Synopsis of the Judgment

The father of the appellants filed a criminal complaint in 2007 alleging forgery of his signature and preparation of false documents in respect of his self‑acquired property. Despite repeated directions from the Judicial Magistrate First Class (JMFC) and the High Court over nearly two decades, the investigation remained incomplete. The original complainant moved the High Court seeking a direction to file a charge‑sheet. The High Court refused to intervene, observing that the JMFC had already passed orders and that appropriate proceedings should be initiated before the JMFC. The Supreme Court set aside the High Court’s order, holding that the right to speedy trial under Article 21 is intrinsically linked to timely completion of investigation. The Court noted that nearly two decades had passed without any meaningful conclusion of the investigation, and that the High Court ought to have exercised its extraordinary jurisdiction. The Court directed the State of Gujarat and Police Station Bhiloda to conclude the investigation within six weeks and file an appropriate report before the JMFC. The State was also directed to file an affidavit regarding disciplinary action against the erring officer and compliance with the directions.

1. Basic Information of the Judgment

Case Title: Sahil Abdulsattar Mansuri and Others v. Safimahamad Fafirbhai Mansuri and Others

Citation: 2026 INSC 626

Criminal Appeal No.: Arising out of SLP (Crl.) No. 17479 of 2025

Bench: Justice Sanjay Karol & Justice Augustine George Masih

Date of Decision: June 4, 2026

Court: Supreme Court of India (Criminal Appellate Jurisdiction)

Impugned Order: Order dated 26th June 2025 of the High Court of Gujarat at Ahmedabad in Special Criminal Application (Direction) No. 2029 of 2024, dismissing the writ petition seeking direction to file charge‑sheet.

2. Legal Framework

Major Laws and Provisions Involved

• Constitution of India, 1950 – Article 21 (right to speedy trial – includes timely completion of investigation), Article 226 (writ jurisdiction of High Courts).

• Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) – Section 528 (inherent powers of High Court – corresponding to Section 482 CrPC).

• Code of Criminal Procedure, 1973 – Section 482 (inherent powers to quash proceedings or issue directions).

• Indian Penal Code, 1860 – Sections 120B (

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