Impact of completed investigation qua accused on necessity of continued detention

When investigating agencies formally state before the trial court that investigation against a specific incarcerated accused has concluded, the primary rationale for pre-trial custody stands significantly diminished. Pre-trial detention is fundamentally intended to facilitate unhindered investigation, prevent interference, and secure the presence of the accused. Once the prosecution complaint or charge-sheet is filed and the agency confirms that custody is no longer required for investigative steps, continued incarceration requires compelling justification. If the evidence against the accused is predominantly documentary in nature and already secured in judicial custody, the risk of evidence tampering becomes minimal. Continuing detention under such conditions serves no recognized investigative purpose and unnecessarily restricts personal liberty. Therefore, completion of investigation qua the accused weighs heavily in favor of enlarging the applicant on regular bail. (Arvind Dham v. Directorate of Enforcement | 2026 INSC 12)