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Supreme Court of India 2022-05-26 allowed

Serious Fraud Investigation Office and Others vs Sahara Housing Investment Corporation Limited and Others

Bench: 2 — D.Y. Chandrachud

In Brief

The Supreme Court set aside interim orders of the Delhi High Court that had stayed investigations into Sahara group companies. The High Court had stayed investigations initiated under Companies Act sections 212 and 219 on three grounds. The Court held that the three-month timeframe in Section 212(3) is directory, not mandatory, so its expiry does not end investigative authority. Second, the six additional companies fell within Section 219(c), allowing investigation of entities whose boards comprise company nominees or act on company directions. Third, the Government need not furnish elaborate reasons when ordering investigations. The Court cautioned against blanket interim orders staying investigations, which impede the investigative process.

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Corporate Law Investigative Procedure Companies Act Interim Relief Administrative Law Extraordinary Jurisdiction

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