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Supreme Court of India 2019-03-27 allowed

SERIOUS FRAUD INVESTIGATION OFFICE vs RAHUL MODI

Bench: 2 — Abhay Manohar Sapre, Uday Umesh Lalit

In Brief

The Supreme Court upheld the arrest of three individuals by the SFIO in a corporate fraud investigation, despite a legal challenge to the timing of their arrest. The Court held that the three-month period prescribed under Section 212(3) of the Companies Act, 2013 for completing investigation is merely directory, not mandatory. Once investigation is assigned to SFIO, the agency's mandate does not terminate upon expiry of the stipulated period and continues until final investigation report submission. The Court also held that High Courts should not entertain habeas corpus petitions challenging arrest validity when valid judicial remand orders exist; such challenges must be pursued through appellate proceedings. The judgment sets aside the High Court's order releasing the accused and directs them to surrender before the Special Court for remand consideration on merits.

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Criminal Procedure Habeas Corpus Corporate Law Fraud Investigation Jurisdiction Statutory Interpretation Investigative Powers Bail and Remand

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