Singh v. State of Haryana, (1996) 11 SCC 709, P.W. 3 intercepted the accused and recovered arms and thereafter, registered the case and proceeded with the investigation. As admitted, he was the person who apprehended the accused and registered and investigated the case and there was no other independent witness examined except the evidence of P.Ws. 2 and 3. The Apex Court rightly held that the complainant should not have proceeded with the investigation, as it impinges upon the impartial investigation. Incidentally, P.W. 2 also accompanied P.W. 3, being a Police Officer. In State v. V. Jayapaul, (2004) 5 SCC 223, the facts are to the effect that the F.I.R. was registered based upon the information received. Thereafter, the said officer proceeded to investigate. On those facts, the Apex Court was pleased to distinguish the earlier decisions and held that there is no bias involved. In State v. V. Jayapaul, (2004) 5 SCC 223, the decisions in Bhagwan Singh v. State of Rajasthan, (1976) 1 SCC 15 and Megha Singh v. State of Haryana, (1996) 11 SCC 709 were considered and held as follows: “6. Though there is no such statutory bar, the premise on which the High Court quashed the proceedings was that the investigation by the same officer who “lodged” the FIR would prejudice the accused inasmuch as the investigating officer cannot be expected to act fairly and objectively. We find no principle or binding authority to hold that the moment the competent police officer, on the basis of information received, makes out an FIR incorporating his name as the informant, he forfeits his right to investigate. If at all, such investigation could only be assailed on the ground of bias or real likelihood of bias on the part of the investigating officer. The question of bias would depend on the facts and circumstances of each case and it is not proper to lay down a broad and unqualified proposition, in the manner in which it has been done by the High Court, that whenever a police officer proceeds to investigate after registering the FIR on his own, the investigation would necessarily be unfair or biased. In the present case, the
