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NCLAT determined SFIO investigation reports are admissible as evidence in proceedings under Section 212(14A) of Companies Act, 2013, despite being deemed equivalent to police reports under Section 173 CrPC. The Tribunal clarified that Section 212(15)'s legal fiction is limited to treating SFIO reports as police reports solely for charge framing purposes, not to make them inadmissible as evidence. Section 223(5) does not affect SFIO report admissibility in Section 212(14A) proceedings. The deeming provision's scope is restricted to its specific context and cannot be extended beyond statutory language. The compilation of documents and SFIO reports submitted remain admissible, with their evidentiary value to be determined during merit-based proceedings.
NCLAT determined SFIO investigation reports are admissible as evidence in proceedings under Section 212(14A) of Companies Act, 2013, despite being deemed equivalent to police reports under Section 173 CrPC. The Tribunal clarified that Section 212(15)'s legal fiction is limited to treating SFIO reports as police reports solely for charge framing purposes, not to make them inadmissible as evidence. Section 223(5) does not affect SFIO report admissibility in Section 212(14A) proceedings. The deeming provision's scope is restricted to its specific context and cannot be extended beyond statutory language. The compilation of documents and SFIO reports submitted remain admissible, with their evidentiary value to be determined during merit-based proceedings.
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