In a criminal justice system, the state is shouldered with the onerous duty to investigate and prosecute offences that mar the societal fabric of the country. The manner in which this duty is discharged becomes a yardstick of fairness in the justice dispensation system. When police hold the power to investigate in perpetuity and exercise it without substantive fetters, then the accused is subjected to a constant fear of stigmatization in society due to protraction of trial or prolonged incarceration in several cases. Section 193(9) of the Bharatiya Nagarik Suraksha Sanhita (‘BNSS’) (Section 173(8) Code of Criminal Procedure (‘CrPC’)) empowers the police to conduct further investigation and file a supplementary chargesheet after the conclusion of the investigation.1 Admittedly, such wide powers are necessary so that the accused are brought to justice. However, the expansive powers are vested in the police without stringent threshold conditions as to at which stage such power may be exercised and under which circumstances should these powers be invoked. In light of the amorphous jurisprudence and conflicting judgments on the issue as discussed in the ensuing sections, powers under Section 193(9) of BNSS become susceptible to misuse. Such wide powers can lead to a multitude of problems like inordinate delay in concluding a trial, multiplicity of proceedings, belated rectification of evidence marshalled by the prosecution and prolonged incarceration. This wide spectrum of problems that Section 193(9) presents runs counter to the essence of the criminal codes in India by tinkering with the right of the accused to a fair and just trial.