The Supreme
Court in case of Mohan Lal vs State of Punjab CRIMINAL APPEAL NO.1880 OF
2011 SC 16Aug 2018 held that:-
— Complainant can’t be the investigating officer. In a case where Report
is submitted by the police officer and on his report FIR was registered,
subsequently he cannot be the investigating officer in that case.
— The Investigating
officer must be an officer senior to the complainant officer.
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