Limited judicial directions cannot support a separate disproportionate assets FIR without lawful authority and State consent.

Earlier court directions confined the inquiry to the Taj Heritage Corridor Project and verification of assets only within that limited context. A later FIR alleging disproportionate assets from 1995 onwards was treated as exceeding that mandate because no specific direction had authorised a separate criminal case on that issue. The Court held that the investigating agency could not equate the two matters, and that in the absence of lawful authority and required State consent under the applicable police establishment framework, the second FIR and the resulting investigation were without jurisdiction and liable to be quashed.

---

---

Issues: Whether the second FIR and the investigation into the petitioner's alleged disproportionate assets were authorised by the earlier directions of the Court and could be sustained in the absence of State consent under the applicable police establishment law.

Analysis: The directions preceding the impugned FIR were confined to the Taj Heritage Corridor Project and to the alleged release and use of Rs. 17 crores in that project. The earlier orders authorised inquiry into irregularities in the project and permitted verification of assets only in that limited context. The Court found that the subsequent FIR against the petitioner alone, relating to alleged disproportionate assets from 1995 onwards, went beyond the subject matter of those directions. It also held that no specific direction had been issued to lodge a separate FIR on the disproportionate assets issue, and that the CBI could not treat the two matters as the same. In the absence of a valid direction and without consent of the State Government, the investigation could not be justified under the statutory framework.

Conclusion: The second FIR and the investigation pursuant to it were held to be without jurisdiction and liable to be quashed in favour of the petitioner.

Ratio Decidendi: Where the Court's earlier directions are confined to a particular subject matter, the investigating agency cannot expand them into a separate criminal inquiry on a different issue, and in the absence of lawful authority and required State consent, the resulting FIR and investigation are ultra vires and unsustainable.

---