New Delhi [India], July 30 : The Delhi High Court has refused to direct the Corporate Affairs Ministry and the Serious Fraud Investigation Office (SFIO) to disclose the orders authorising an investigation into the affairs of Reliance Home Finance Limited, Reliance Communications Limited and other companies, observing that disclosure of such material at the preliminary stage could adversely affect the ongoing investigation extending beyond the petitioner alone.
Dismissing a writ petition filed by Mandke Foundation, Justice Swarana Kanta Sharma held that the petitioner had failed to establish any enforceable right to seek copies of the Ministry's investigation orders dated October 30, 2025 and November 12, 2025, or the material forming the basis of those orders while the SFIO investigation was still underway.
The Court clarified that if any action prejudicial to the petitioner is taken at a later stage, it would remain open to the petitioner to avail all remedies available in law.
The Court observed that the proceedings initiated by the SFIO were presently at a preliminary stage and that the notice issued to the petitioner merely required it to furnish information and documents under Section 217 of the Companies Act.
It noted that the notice itself informed the petitioner that the Central Government had directed an investigation into the affairs of Reliance Home Finance Limited and other related companies, and that analysis of financial transactions had revealed that the petitioner had directly or indirectly entered into financial dealings with the companies under investigation.
Rejecting the contention that the petitioner had been kept completely in the dark, the High Court observed that the SFIO notice adequately disclosed the nature and purpose of the information sought.
According to the Court, the petitioner was informed that the documents were being sought in connection with an ongoing investigation and was also made aware of the categories of financial records and bank statements required for the specified period.
The Court further noted that the petitioner had first received the SFIO notice on April 11, followed by a reminder on May 27, directing submission of information by June 5.
Although the petitioner responded by expressing willingness to cooperate and sought copies of the MCA orders along with six weeks to retrieve voluminous archival records, it admittedly did not furnish the information sought.
In these circumstances, the Court held that the subsequent summons issued to the petitioner's present Director Tina A. Ambani and former Director Jai Anshul A. Ambani had to be viewed in the backdrop of the petitioner's failure to comply with the earlier notice and reminder.
The High Court also accepted the respondents' contention that the SFIO investigation formed part of a much larger probe involving several companies and that related proceedings concerning the same investigation were pending before the Bombay High Court.
The Court observed that the MCA's investigation orders contained sensitive information relating to multiple entities and that disclosure of such material at this stage could prejudice not only the present investigation but also connected proceedings. It found no reason to disregard the government's submission that premature disclosure could adversely impact the ongoing investigation.
Holding that no enforceable legal right had accrued in favour of the petitioner to demand disclosure of the investigation orders at this stage, the Court dismissed the writ petition as devoid of merit and also disposed of the pending application.
Mandke Foundation, a Section 8 company engaged in charitable activities and running the Kokilaben Dhirubhai Ambani Hospital and Medical Research Institute in Mumbai, approached the Delhi High Court after the SFIO initiated steps requiring it to participate in an investigation ordered by the Ministry of Corporate Affairs under Section 212 of the Companies Act.
The Foundation challenged the authorities' refusal to furnish copies of the MCA orders dated October 30 and November 12, 2025, which had authorised the SFIO investigation into Reliance Home Finance Limited, Reliance Communications Limited and other companies.
According to the petition, the SFIO's notice dated April 11 required the Foundation to provide extensive financial records, bank statements and transaction details covering the period from financial year 2008-09 to 2025-26 on the ground that analysis of banking transactions indicated direct or indirect financial dealings with the companies under investigation.
The petitioner argued that without access to the MCA orders and the material underlying them, it could neither understand the scope of the investigation nor effectively exercise its legal remedies. The Union Government opposed the plea, contending that disclosure at the investigation stage would compromise the probe, reveal the investigative roadmap and potentially result in destruction of evidence.