In which judgment, the Hon'ble Supreme Court has laid down that having taken cognizance of a case, the Magistrate cannot direct the Police to conduct further investigation:
Verified Answer
A. State of Haryana v. Choudhary Bhajan Lal; AIR 1992 SC 604
B. M/s Jayanti Vitamin v. Chaitanya Kumar; AIR 1992 SC 1930
C. Amrutbhai Shambhubhai Patel v. Sumanbhai Kantibhai Patel & Ors.; AIR 2017 SC 774
D. Hemant Dhasmana v. CBI; AIR 2001 SC 2721
Explanation:
In Amrutbhai Shambhubhai Patel v. Sumanbhai Kantibhai Patel & Ors., the Supreme Court held that once a Magistrate takes cognizance of an offence and proceeds to issue process under Chapter XV or XVI of the Cr.P.C., he cannot thereafter revert to the pre-cognizance stage and direct further investigation under Section 156(3) of the Cr.P.C. This judgment clarified the limits of a Magistrate's power to direct further investigation after taking cognizance.