The correct answer is (d).
In the case of Vinod Katara vs State of Uttar Pradesh, the Supreme Court held that the High Court in exercise of its inherent power can direct further investigation or re-investigation in appropriate cases. The Court held that the High Court has the power to direct further investigation or re-investigation in cases where it is satisfied that the investigation conducted by the police is not fair or proper. The Court also held that the High Court can direct further investigation or re-investigation even if the charge sheet has been filed and the trial has commenced.
The Court observed that the power of the High Court to direct further investigation or re-investigation is an inherent power and is not dependent on any specific provision of law. The Court also observed that the power of the High Court to direct further investigation or re-investigation is a discretionary power and the Court will exercise this power only in cases where it is satisfied that it is necessary to do so in the interest of justice.
The Court further observed that the power of the High Court to direct further investigation or re-investigation is not limited to cases where there is a prima facie case against the accused. The Court held that the High Court can also direct further investigation or re-investigation in cases where there is no prima facie case against the accused, but the Court is satisfied that the investigation conducted by the police is not fair or proper.
The Court’s decision in the case of Vinod Katara vs State of Uttar Pradesh is a significant decision as it clarifies the power of the High Court to direct further investigation or re-investigation in appropriate cases. The Court’s decision will help to ensure that justice is done in cases where the investigation conducted by the police is not fair or proper.
The other options are incorrect because they do not deal with the power of the High Court to direct further investigation or re-investigation.