Supervision of ongoing investigation remains exceptional where agencies are already seized of fraud and money-laundering enquiries.

A petition seeking directions to compel, monitor and expedite investigation into alleged fraud and money-laundering was declined because the concerned investigative agencies had already commenced and continued their enquiries. The Court noted that status reports from the Economic Offences Wing, the Enforcement Directorate and the Serious Fraud Investigation Office showed ongoing investigation, and reiterated that supervision of investigation is exceptional and the conduct of investigation remains primarily with the investigating agency. It also observed that parallel remedies were available before the NCLT and RERA authorities, leaving no basis for the additional mandamus sought.

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Issues: Whether further directions were required to compel, monitor, or expedite investigation into the alleged fraud and money-laundering transactions when the concerned investigative agencies were already seized of the matter.

Analysis: The petition sought directions for investigation, freezing of assets, and monitoring of ongoing proceedings. The Court noted that the Economic Offences Wing, the Enforcement Directorate, and the Serious Fraud Investigation Office had all filed status reports showing that enquiries and investigations were already in progress. The Court reiterated that supervision of investigation is warranted only in rare cases and that the conduct, course, and manner of investigation lie primarily within the domain of the investigating agency. In view of the continuing investigation and the availability of other remedies before the NCLT and RERA authorities, the Court found no basis to issue the further mandamus sought in the petition.

Conclusion: No further directions were warranted, and the petition was not allowed on merits.

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