The Delhi High Court rejected a plea by Mandke Foundation, an NGO linked to Tina Ambani, seeking access to material used by the Serious Fraud Investigation Office in its probe against Reliance group companies. Tina Ambani is a director of Mandke Foundation, which runs Kokilaben Dhirubhai Ambani Hospital in Mumbai. The court upheld SFIO's position that investigation material is confidential and not subject to disclosure to parties under scrutiny during an ongoing investigation.

This case tests a critical statutory mechanism under Section 212 of the Companies Act, 2013, which governs SFIO investigations. SFIO — the Serious Fraud Investigation Office — is a multi-disciplinary body under the Ministry of Corporate Affairs that investigates serious fraud in companies. When the Central Government assigns an investigation to SFIO under Section 212(1), the investigation is treated as a serious criminal proceeding, and the SFIO has sweeping powers including arrest, search, and seizure.

The key exam-testable point here is the confidentiality of investigation material. During an SFIO investigation, the material gathered — documents, statements, digital records — is not required to be shared with the subject of investigation. This principle flows from the adversarial nature of fraud investigation: premature disclosure could compromise evidence, allow document destruction, or help accused parties coordinate defences.

The NGO's plea was essentially a demand for access to the evidentiary basis of the probe, which courts have consistently refused. The High Court's ruling reinforces that SFIO's investigative material enjoys confidentiality protection and that third parties — even those claiming to be aggrieved — cannot compel disclosure during a live investigation.

For CLAT PG, this case connects to Section 212 scope, SFIO's special powers compared to Registrar of Companies (ROC), and the procedural immunities that shield investigation material. The examiner frequently tests which body has power to investigate, what triggers an SFIO investigation, and the distinction between SFIO and ROC jurisdiction.