State reorganisation does not end prior consent orders or jurisdictional notifications for ongoing criminal investigations.

On State reorganisation, existing laws, notifications, government orders and consent arrangements continue in the successor States until altered, repealed or amended. Applying that principle, the text states that earlier general consent for CBI investigation and later extending orders remained effective after bifurcation, so CBI authority to register and investigate the FIRs was not defeated merely because the offences involved State employees or occurred in districts within Andhra Pradesh. It also states that the notification conferring jurisdiction on the Hyderabad Special Judge continued to operate, so the court's jurisdiction and the ensuing proceedings were not invalidated on reorganisation grounds.

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Issues: (i) Whether the CBI lacked authority to register and investigate the FIRs for want of State consent after the bifurcation of the erstwhile State of Andhra Pradesh. (ii) Whether the Special Judge at Hyderabad lacked jurisdiction, and whether the pre-existing notifications and government orders continued to operate after reorganisation of the State.

Issue (i): Whether the CBI lacked authority to register and investigate the FIRs for want of State consent after the bifurcation of the erstwhile State of Andhra Pradesh.

Analysis: The statutory scheme under Sections 5 and 6 of the Delhi Special Police Establishment Act, 1946 permits extension of CBI powers to an area in a State subject to consent of that State. The circular issued under Section 3 of the Andhra Pradesh Re-Organisation Act, 2014 treated existing laws, notifications, orders and other instruments in force immediately before the appointed day as continuing in the successor States until altered, repealed or amended. The general consent earlier granted for CBI investigation, together with later orders extending that consent, continued to operate in the successor State framework. The offences alleged were under the Prevention of Corruption Act, 1988, and the relevant CBI authority could not be denied merely because the accused were State-based employees or because the alleged acts occurred in districts that remained within Andhra Pradesh.

Conclusion: The objection based on absence of consent was rejected and the CBI was held competent to register and investigate the FIRs.

Issue (ii): Whether the Special Judge at Hyderabad lacked jurisdiction, and whether the pre-existing notifications and government orders continued to operate after reorganisation of the State.

Analysis: The notifications designating the CBI Court and the government orders regulating jurisdiction were treated as laws/instruments continuing under the reorganisation circular. The Court held that the earlier notification conferring jurisdiction on the Hyderabad CBI Court over the relevant districts did not automatically cease on bifurcation, and the subsequent transfer of cases was also found to be in accordance with law. On that footing, the Special Court's jurisdiction and the later proceedings could not be invalidated merely because the reorganisation had occurred or because a fresh notification was not issued in the manner suggested by the respondents.

Conclusion: The challenge to the Special Judge's jurisdiction and the consequent quashing of proceedings was rejected.

Final Conclusion: The impugned judgment quashing the FIRs, chargesheets and further proceedings could not be sustained, and the criminal cases were restored for continuation of trial in accordance with law.

Ratio Decidendi: On State reorganisation, existing laws, notifications and consent orders continue in the successor States until they are altered, repealed or amended, and CBI jurisdiction under the DSPE Act is not defeated where the pre-existing legal regime remains operative.

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