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of <h1>SFIO investigation report under Section 212(12) admissible as evidence under Section 212(14A)/223(5) akin to Section 173 CrPC</h1> <h3>Kalpesh Mehta Versus Union Of India & Ors.</h3> SC held that the SFIO investigation report submitted under Section 212(12) and considered under Section 212(14A) / Section 223(5) is admissible as ... Interpretation of Section 212(15) and sub-section (5) of Section 223 - Legality of investigation Report submitted by the Serious Fraud Investigation Office (SFIO) under Section 212(12) of the Companies Act, 2013 - admissible as legal evidence or not, as SFIO Report have been equated as report prepared under Section 173 of the Code of Criminal Procedure (CrPC) 1973 - relevance of 2nd SFIO Report and the Compilation of Documents filed by the Respondent on 07.02.2024 before the NCLT - no sufficient pleadings in the Company Petition/ Miscellaneous Application filed by the Respondent with respect to the SFIO Report and documents and Compilation of the Documents - it was held by NCLAT that the SFIO Report is admissible in proceedings under Section 212(14A), and the NCLT did not err in considering the report and associated documents. HELD THAT:- The civil appeal is dismissed. 'Delay in refiling is condoned.' The Court, applying the precedent and order dated 19.05.2025 in C.A. No. 6645/2025 [Deloitte Haskins and Sells LLP vs. Union of India and Others], adjudicated that the present appeal must follow that earlier determination and accordingly 'we dismiss this Civil Appeal.' The procedural relief sought for condonation of delay was granted, but on merits or by application of the cited authority the appeal could not be sustained. All pending applications ancillary to the appeal are directed to stand disposed of. The decision is strictly interlocutory/procedural in scope, grounded on adherence to the prior ruling referenced, and operates to terminate further proceedings in the present civil appeal.
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