That case, AKM Shafiqur Rahman v The State, concerned a different law: the time limit in section 20Ka of the Anti-Corruption Commission Act 2004.[2] It is not a ruling on the Code of Criminal Procedure. But it matters, because Parliament has now built a similar mechanism for ordinary police investigations.

What the law requires:

Section 173B, inserted by the Code of Criminal Procedure (Amendment) Act 2026 and treated as in force from 10 August 2025, says every police investigation must be completed within 60 working days of the police receiving the information about the offence. If an investigator cannot finish for reasonable cause, he or she must record the reasons in the case diary, apply to a Magistrate stating the specific grounds and the extra time needed, and send a copy to the supervising officer. The Magistrate may extend the time as seems reasonable.[3]

If the extended time also runs out, the investigator must report the reasons in writing. The Magistrate may then direct another officer to take over, or treat the delay as incompetence or misconduct, order a note in the officer's annual confidential report, and direct the proper authority to act under service rules. Separately, after a trial, a court may record findings of misconduct or incompetence against an investigator who, through negligence or to protect someone, failed to collect or consider admissible evidence, treated a person who should have

been accused as a witness, or failed without justification to examine a key witness (section 173B(7)). That power is not tied to the clock.[4]

This is not the first deadline in the law. Section 167(5) lets a court grant bail when an investigation is unfinished after 120 days, though judges have treated that as discretionary. Nor does section 173B say that a missed deadline affects the case itself, and High Court decisions on comparable limits have treated them as obligatory but not fatal to the case.[5] As far as open sources show, no reported ruling yet interprets section 173B.

The accountability gap:

The law asks the investigator for ‘specific grounds’. It asks nothing comparable of the Magistrate, who ‘may, by order’ extend the time.[6] Nothing in the section requires that order to say why. The same Act requires reasons when police decide whether to arrest and when a Magistrate directs action against an officer who breached the arrest rules (sections 54 and 67A).[7] That suggests Parliament did not intend such a duty here, although a court could read one in.

Section 173B also sets no limit on the number or length of extensions, and does not specify how a Magistrate is alerted when the initial 60-working-day period expires without an extension application. Most telling is replacement. A Magistrate may direct ‘another officer’, yet the section is silent on how long the new officer has. The clock runs from the date of the information, which may suggest no fresh start, but the text does not say so.[8] The Anti-Corruption Commission Act, by contrast, gave a replacement officer 90 working days. Even so, in Shafiqur Rahman the repeated appointment of new officers did not bring the investigation to an end.[9]

Why flexibility still matters :

None of this is an argument for rigid deadlines. Some investigations legitimately need more than 60 working days. In Shafiqur Rahman, a handwriting report took about five months to come back from the forensic laboratory.[1] In a 2024 order on anticipatory bail, the Appellate Division observed that investigating agencies sometimes need more time to investigate properly.[2] And an investigator should not be blamed for delay he or she did not cause. It is sensible that section 173B makes discipline something a Magistrate ‘may’ order, not must.

Magistrates are also stretched. The Law Minister told Parliament that about 2.4 million criminal cases were pending in subordinate courts at the end of March 2026.[3] Any reform must be light enough to be used.

Three practical reforms:

First, require reasoned extension orders. They need not be long: what remains to be done, why it takes time, and whether the cause lies with the investigator or elsewhere, such as a forensic report. That gives the supervising officer, a higher court and, in time, researchers something to examine, and it protects investigators from blame for outside delay. This could be done by amendment or by a direction from the High Court Division, which supervises the lower courts.[4]

Second, set a timetable for replacement officers. When a Magistrate directs another officer to take over, the order should fix a date, as the Anti-Corruption Commission Act does with its 90 working days, so that a change of officer does not quietly restart the clock.[5]

Third, publish aggregate, anonymised figures: how many investigations pass 60 working days, how many extensions are granted, how many cases are reassigned, and how many officers are referred for action under service rules. I could find no published figures on how often extensions are sought or granted. Police Headquarters already compiles case-status numbers for some high-profile cases, such as the July 2024 uprising cases.[6] Counting would show whether the 60-working-day rule is changing practice, and whether 60 working days is realistic.