This is in continuation of my earlier write up published in Criminal Law Journal November, 2001 Journal Section, page 161 under the same title. It was observed in the Article that the controversy has been settled by Hon’ble Supreme Court in State of U. P. v. Ram Babu, AIR 1980 SC 791 by holding that during investigation the Magistrate cannot direct a person to give his specimen handwriting etc. But it appears that controversy has not been settled and is raging up. Recently in Sanjay Goel v. State of U. P., 2002 Cri LJ 625 (All), the Hon’ble Allahabad High Court held that the Magistrate during investigation can direct accused to give specimen writing under the provisions of S. 164 of the Code of Criminal Procedure (hereinafter called ‘the Code’). Under Section 164 of the Code, the Magistrate can record any confession or statement of any accused or a witness in the course of an investigation and before the commencement of inquiry or tria ....