SFIO corporate fraud probe including related IPC offences: investigation power upheld; challenge to SFIO remit dismissed.

The dominant issue was whether the Serious Fraud Investigation Office (SFIO), constituted under the Companies Act, is legally barred from investigating offences under the IPC while conducting or continuing investigation into corporate fraud. The HC held that, on a conjoint and harmonious reading of the CrPC and the Companies Act provisions governing investigation, the SFIO's investigatory remit is not confined to Companies Act offences and does not exclude investigation into IPC offences arising from the same facts. The SC declined to interfere with that determination and dismissed the special leave petition.

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The special leave petition challenging the impugned High Court judgment was dismissed, with the Court stating: "We are not inclined to interfere with the impugned judgment and hence, the special leave petition is dismissed." The Court expressly left unresolved the legal issue "as to whether the Officer(s) of the Serious Fraud Investigation Office (SFIO) are police officer(s) under the Code of Criminal Procedure, 1973." It clarified that this question "did not directly arise for consideration before the High Court" and that "the impugned judgment will not be treated as a precedent on the said aspect." Any pending applications were disposed of.

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