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    <title>2023 (12) TMI 1019 - DELHI HIGH COURT</title>
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    <description>Section 219 of the Companies Act was read as governing investigation into related companies and connected persons, not as creating a separate approval barrier for a key managerial personnel already covered by a Section 212 investigation; any absence of approval for the related company was treated as a procedural defect that would not, by itself, invalidate proceedings absent prejudice. The Serious Fraud Investigation Office was also said not to be barred from investigating Indian Penal Code offences forming part of the same transaction, because the Companies Act and Criminal Procedure Code operate harmoniously and the investigation report functions as a police report. Further investigation after filing the report was held to remain permissible under the criminal procedure framework.</description>
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