Company fraud investigations may be shifted to SFIO where overlapping FIRs risk duplication and inconsistent police inquiries.

Allegations centred on company affairs, including deposits, dividend non-payment, fund diversion, account irregularities, and related corporate records, were treated as matters requiring specialised corporate and forensic scrutiny under the Companies Act. The text states that such allegations may fall within the Serious Fraud Investigation Office's investigative remit rather than ordinary police inquiry. It also notes that where multiple FIRs concern substantially similar company-related transactions across different police stations, consolidation before one competent agency is appropriate to avoid duplication, inconsistency, and harassment. The operative effect described is transfer of the investigations to the SFIO, with consequential directions for cooperation.

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Issues: (i) Whether the alleged offences arising out of the company's affairs fell within the purview of investigation by the Serious Fraud Investigation Office rather than investigation by the police; (ii) Whether registration and parallel investigation of multiple First Information Reports in different police stations in respect of the same alleged company-related transactions warranted transfer of the cases to a single agency.

Issue (i): Whether the alleged offences arising out of the company's affairs fell within the purview of investigation by the Serious Fraud Investigation Office rather than investigation by the police.

Analysis: The company-related allegations concerned collection of deposits, non-payment of dividends, diversion of funds, and possible irregularities in accounts and corporate affairs. The statutory scheme under the Companies Act, 2013 contemplates investigation into company affairs by the Central Government and, where assigned, by the Serious Fraud Investigation Office. The Court treated such matters as requiring specialised corporate and forensic examination rather than ordinary police investigation, particularly where questions of accounts, compliance, share arrangements, banking records, and related corporate records arise. It held that the investigation mechanism under the Companies Act is intended to deal with serious fraud and that the specialised agency is better equipped for such inquiry.

Conclusion: The issue was answered in favour of transfer to the Serious Fraud Investigation Office and against exclusive police investigation of the company-law related allegations.

Issue (ii): Whether registration and parallel investigation of multiple First Information Reports in different police stations in respect of the same alleged company-related transactions warranted transfer of the cases to a single agency.

Analysis: The Court noted that multiple complaints had been registered across different police stations on substantially similar allegations against the same business group. It found that parallel investigation by several police stations into overlapping transactions would lead to confusion, inconsistency, duplication of effort, and undue harassment to the accused, while also affecting the fairness and efficiency of investigation. In the interests of fair investigation and to avoid conflicting approaches, the Court considered it appropriate that all such matters be consolidated before one competent agency. It therefore directed the local police to assign the investigations to the Serious Fraud Investigation Office and also issued consequential directions for the accused's appearance and cooperation during the SFIO investigation.

Conclusion: The issue was answered in favour of consolidation and transfer of all such cases to the Serious Fraud Investigation Office.

Final Conclusion: The writ petitions were allowed in part by shifting the investigation of the subject matters to the specialised corporate fraud agency and by granting consequential reliefs and directions, while not determining the merits of the underlying criminal allegations.

Ratio Decidendi: Where allegations principally concern fraud or irregularities in the affairs of a company, involving specialised corporate and forensic assessment, investigation may be transferred to the statutory specialised agency under the Companies Act to secure fair, effective, and non-duplicative investigation.

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