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Supreme Court of India 2024-02-13 allowed

DIRECTORATE OF ENFORCEMENT vs NIRAJ TYAGI & ORS

Bench: 2 — Bela M. Trivedi, Prasanna B. Varale

In Brief

This judgment addresses the High Court's authority to stay criminal investigations and bar arrest of accused persons under Section 482 of the Criminal Procedure Code. The case arose from FIRs filed by borrowers (Shipra Group) against India Bulls Housing Finance Limited and its officers following loan recovery proceedings under the SARFAESI Act. The High Court had granted interim orders staying investigations and prohibiting coercive action. The Supreme Court allowed the appeals, holding that the High Court cannot stay cognizable offence investigations at the nascent stage or grant blanket arrest restraints without an application for anticipatory bail. Such orders violate settled principles and the guidelines from Neeharika Infrastructure. The Court emphasized that inherent powers under Section 482 CrPC must be exercised sparingly and cautiously, not according to judicial whim.

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Criminal Procedure Inherent Powers Investigation Quashing of FIR Money Laundering SARFAESI Act High Court Powers

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