Independent investigation into public fund irregularities justified where serious suspicion and bias concerns made local inquiry unreliable.

Allegations of large-scale embezzlement and financial irregularities in a public scheme justified an independent investigation where the material showed prima facie misuse of public funds and an inadequate inquiry. The Court applied the principle that public office is held in trust and that constitutional courts may order a fair and unbiased probe when there is serious suspicion of wrongdoing and a reasonable apprehension that the local investigation may not be independent. On that basis, it directed investigation by the Central Bureau of Investigation to secure an impartial inquiry.

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Issues: Whether, on the allegation of large-scale embezzlement and financial irregularities in a public scheme, the Court should direct investigation by the Central Bureau of Investigation.

Analysis: The petition alleged siphoning of public funds on a massive scale, and the material placed before the Court, including the State's submissions, indicated prima facie financial irregularities and inadequate inquiry. The Court relied on the principle that public office is held in trust, corruption undermines rule of law, and constitutional courts may direct a fair and independent investigation where the facts disclose a serious suspicion of wrongdoing and there is apprehension that the local investigation may be influenced. The Court treated the circumstances as requiring an independent agency to ensure an unbiased investigation.

Conclusion: The direction for investigation by the Central Bureau of Investigation was issued in favour of the petitioner.

Ratio Decidendi: Where allegations disclose prima facie serious misuse of public funds and there is a reasonable apprehension that an ordinary investigation may not be fair or independent, a constitutional court may direct investigation by the Central Bureau of Investigation to secure an impartial inquiry.

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