The Hon’ble Supreme Court recently while considering the question as to whether an accused was entitled to the benefit of default bail in terms of Section 167(2), CrPC on the ground that the investigation qua some of the accused named in the FIR was pending, though the same was complete against him, and the report in terms of Section 173 (2), CrPC was filed within prescribed time against him, held that the benefit of proviso to sub-section (2) of Section 167 CrPC would be available to the offender only when a charge-sheet is not filed and the investigation is kept pending against him, however, once a charge-sheet is filed, the said right ceases. The Apex Court further observed that once the court is satisfied about the commission of an offence from the material produced along with the charge-sheet, and takes cognizance of the offence allegedly committed by the accused, it is immaterial whether the further investigation in terms of Section 173(8) is pending or not. The pendency of further investigation would not vitiate the charge-sheet and would not entitle the accused to default bail for the reason of it being incomplete.