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of <h1>Admissibility of SFIO report under s.212(12) treated as akin to s.173 CrPC in s.212(14A) proceedings</h1> <h3>Udayan Sen Versus Union Of India & Ors.</h3> The SC dismissed the civil appeal, upholding the NCLAT/NCLT approach that an SFIO investigation report under s.212(12) of the Companies Act, 2013 may be ... 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 also dismissed. SUPREME COURT OF INDIA (Citation: TMI) 'Following the order dated 08.08.2025 passed in Civil Appeal Diary No. 20766/2025 (Kalpesh Mehta vs. Union of India & Ors.) and order dated 19.05.2025 passed in Civil Appeal No. 6645/2025 (Deloitte Haskins and Sells LLP), this Civil Appeal is also dismissed.' The Court disposes of the Civil Appeal by adherence to the precedent and directions contained in those prior orders. Consistent procedural relief: 'Pending application(s), if any, shall stand disposed of.' The operative outcome is dismissal of the appeal and final disposal of any outstanding applications, with the judgment resting on the cited earlier orders.
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