Territorial jurisdiction and SFIO primacy under company fraud law barred parallel CBI investigation in the same transaction.

Territorial jurisdiction under Section 482 CrPC was treated as depending on where the FIR was registered, not on where the alleged offence arose, so the High Court could entertain the petition because the CBI office that registered the FIR lay within its territory. On the Companies Act issues, alleged company fraud falling within Section 447 was held to fall within the special investigative scheme of Section 212, which gives primacy to SFIO investigation over parallel agency action in the same transaction. Because the matter had already been entrusted to the SFIO and was under its proceedings, the later CBI investigation was held impermissible; the separate Prevention of Corruption Act reference did not alter that result.

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Issues: (i) whether the High Court had territorial jurisdiction to examine the validity of the FIR on the basis that the registered office of the investigating agency was within its jurisdiction; and (ii) whether the CBI could investigate allegations constituting fraud under the Companies Act, 2013 in view of the statutory scheme under Section 212.

Issue (i): whether the High Court had territorial jurisdiction to examine the validity of the FIR on the basis that the registered office of the investigating agency was within its jurisdiction

Analysis: The power under Section 482 of the Code of Criminal Procedure, 1973 was held to depend on the situs of the authority that registered the FIR, and not on the place where the alleged offence occurred in whole or in part. Cause of action was treated as foreign to criminal law for this purpose. Since the CBI office that registered the impugned FIR was located within the territorial limits of the Court, the objection to maintainability on territorial grounds was rejected.

Conclusion: The High Court had territorial jurisdiction to entertain the petition.

Issue (ii): whether the CBI could investigate allegations constituting fraud under the Companies Act, 2013 in view of the statutory scheme under Section 212

Analysis: The allegations were examined as arising from the affairs of the company and were found to constitute fraud within the meaning of Section 447 of the Companies Act, 2013. Section 212 was treated as providing a special investigative mechanism through the SFIO for offences covered by the Companies Act, 2013, with exclusive primacy over parallel investigation by other agencies in relation to the same transaction. Since the Central Government had already entrusted the matter to the SFIO and the SFIO had investigated and proceeded before the Special Court, the subsequent CBI investigation was held to lack authority. The invocation of the Prevention of Corruption Act did not alter the result, as the FIR did not disclose the essential ingredients necessary to sustain that distinct allegation.

Conclusion: The CBI was not competent to continue the investigation, and the impugned FIR proceedings against the petitioners were quashed.

Final Conclusion: The petitions succeeded, the criminal proceedings in the impugned FIRs were set aside as against the petitioners, and the information collected by the CBI was permitted to be placed before the SFIO in the pending proceedings.

Ratio Decidendi: Where allegations relate to fraud in the affairs of a company and fall within the statutory field occupied by Section 212 of the Companies Act, 2013, the SFIO's investigation prevails and other agencies cannot continue a parallel investigation for the same transaction.

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