The Business Case is an assessment and/or feasibility study which becomes an input to the Charter. It is used as a basis for a future project. In this regard, a Business Case is complete when it meets its goals. This study is then used with the Project, if that is the need, to support its justification.
The Business Case in a way is a self contained study, not something really closed, but something that could be used during a project.
I would also have to say that a Business Case itself, could be the result of a project meant to create one.