0.1 Context

0.1.1 The article examines when and how courts may interfere in an ongoing criminal investigation.
0.1.2 It focuses on judicial orders using the phrase “no coercive steps / coercive measures” and the legal confusion surrounding it.

0.2 Supreme Court Case: State of U.P. & Anr v. Mohd Arshad Khan & Anr (December 2025)

0.2.1 The Supreme Court set aside an order of the Allahabad High Court.
0.2.2 The High Court had directed a time-bound investigation and granted protection from coercive action.
0.2.3 The Supreme Court held that directing investigations in this manner must be an exception rather than the norm.
0.2.4 High Courts should interfere only where delay in investigation itself causes prejudice to the accused.

0.3 Grant of Protection Without Quashing the FIR

0.3.1 The petitioner had sought quashing of the FIR as the main relief.
0.3.2 The High Court did not quash the FIR, meaning the investigation was allowed to continue.
0.3.3 Despite this, the High Court granted protection from arrest or coercive action.
0.3.4 The Supreme Court held this to be unjustified, as protection was granted without granting the principal relief.
0.3.5 The Court clarified that such protection should not be given as a substitute for quashing an FIR.

0.4 Meaning of “Coercive Measures”

0.4.1 The phrase “coercive measures” is frequently used in interim court orders.
0.4.2 In Satya Prakash Bagla v. State & Ors., the Delhi High Court examined its meaning.
0.4.3 The Court held that “coercive measures” does not include freezing of bank accounts during investigation.
0.4.4 The expression was intended to relate only to personal liberty, not to stop lawful investigative steps.

0.5 When Can Courts Interfere in Investigations?

0.5.1 A three-judge Bench of the Supreme Court in Neeharika Infrastructure (P) Ltd. v. State of Maharashtra (2021) laid down governing principles.
0.5.2 Police have a statutory right and duty under the CrPC to investigate cognisable offences.
0.5.3 Courts should not interfere with investigations into such offences as a routine matter.
0.5.4 Interference is justified only where the FIR discloses no offence at all.
0.5.5 Courts must avoid usurping the jurisdiction of the police, except in exceptional cases to prevent miscarriage of justice.

0.6 Interim Orders During Investigation

0.6.1 High Courts have sometimes passed interim orders stating “no coercive steps shall be taken”.
0.6.2 The Supreme Court observed that such orders are not justified when passed without reasons.
0.6.3 Courts should not pass orders that effectively stall arrests or investigations during the entire investigative period.
0.6.4 The Supreme Court dismissed petitions seeking such protection under Section 482 CrPC (Section 528 BNSS) and Article 226.

0.7 Requirement of Clarity in “No Coercive Steps” Orders

0.7.1 The phrase “no coercive steps” is vague and broad.
0.7.2 If a High Court intends to stay an investigation, it must explicitly state so.
0.7.3 The Court must also assign reasons, even if briefly, showing application of mind.
0.7.4 Vague wording can lead to misunderstanding and misuse by investigating agencies or accused persons.

0.9 Legal Provisions Referenced

0.9.1 Section 482 CrPC (now Section 528 BNSS) — inherent powers of High Courts.
0.9.2 Article 226 of the Constitution — writ jurisdiction.
0.9.3 The Supreme Court cautioned against routine invocation of these powers to halt investigations.