The Supreme Court held that the Central Government can authorise any officer, not just the SFIO Director, to file complaints for corporate fraud under the Companies Act, 2013. The ruling clarifies Section 212(14), which grants the Central Government discretion to designate an authorised officer for filing such complaints. This widens the prosecutorial mechanism beyond the SFIO Director and settles a contested interpretation about who holds standing to initiate fraud proceedings under the Act.

Section 212 of the Companies Act, 2013 governs investigations by the Serious Fraud Investigation Office (SFIO). Sub-section (14) provides that the Central Government may authorise any officer to file a complaint in court upon completion of investigation. The critical dispute before the Supreme Court was whether only the SFIO Director had this authority, or whether the Central Government could delegate it to any officer it chose.

The Court resolved this in favour of flexibility: the statutory language — 'any officer authorised by the Central Government' — is permissive and does not restrict the power exclusively to the SFIO Director. The SFIO Director is one possible authorised officer, not the mandatory one.

For CLAT PG, this matters because Section 212 is the most tested SFIO provision. Examiners probe: (a) what triggers an SFIO investigation (Central Government order, court order, or Serious Fraud Investigation Office's own report); (b) the time limits for investigation (60 days, extendable by 180 days, further extendable with special court permission); (c) who can arrest without a warrant (SFIO officers under Section 212(8)); and (d) the director liability standard — a director is liable if they had knowledge or connived in the fraud.

This ruling adds a new testable dimension: the complaint-filing authority under Section 212(14) is not the SFIO Director by default but whoever the Central Government authorises. Examiners can now frame a question asking which officer MUST file the complaint — and the correct answer is that no single officer is mandated; authority rests with whomever the Central Government designates.