In which of the following cases the Supreme Court held that "The law does not mandate taking of prior…

In State of Andhra Pradesh v A.S. Peter (2008) the Supreme Court held that the law does not mandate prior permission of the court for further investigation under section 173(8) CrPC, even after a charge-sheet has been filed, as it is a statutory right of the police; it distinguished further investigation from fresh investigation or reinvestigation. The other cases do not lay down this proposition.

Current law: From 1 July 2024, the corresponding provision for proceedings governed by the Bharatiya Nagarik Suraksha Sanhita 2023 is section 193(9). The proviso now expressly requires the trial court's permission for further investigation during trial and completion within ninety days, extendable with that court's permission. Section 531 saves the specified pending proceedings under the earlier Code.