High Court Declines to Quash Lokpal-Ordered CBI Investigation into Alleged Corruption and Disproportionate Assets

The petitioner, a bank employee, challenged an order passed by the Lokpal of India. Previously, the Anti-Corruption Bureau (ACB) allegedly recovered 2 kg of gold from the petitioner’s scooter during a 2021 search relating to a different crime.

The petitioner alleged the gold was planted by ACB officials and filed a complaint with the Civil Lines Police Station, which resulted in a closure report stating no cognizable offence was found.

Following an anonymous complaint, the Lokpal of India passed an order on 27.03.2026, directing the CBI to investigate allegations against the petitioner regarding the illegal storage of gold for bullion traders and his potential criminal liability or possession of disproportionate assets.

The petitioner sought to quash the Lokpal's order and the police inquiry report, and requested a forensic examination of hard drives containing CCTV footage.

1. Whether the Lokpal of India’s order directing a CBI investigation into the petitioner’s conduct and assets is legally sustainable.

2. Whether the petitioner is entitled to protection against coercive action (arrest) during the pendency of the CBI investigation.

The court operated under Article 226 of the Constitution of India regarding the writ jurisdiction for quashing orders.

It primarily considered Sections 20(3) and related provisions of the Lokpal and Lokayuktas Act, 2013, which empower the Lokpal to direct an investigation by an agency like the CBI if a prima facie case exists to proceed against a public servant.

The principle of judicial restraint in interfering with ongoing investigations was applied, particularly where the investigating agency (CBI) clarifies that no arrest order has been issued.

The Court observed that the Lokpal directed a "deeper probe" after receiving a status report from the CBI and the police, which indicated that the petitioner's own complaint against ACB officials had been closed.

The Lokpal's order specifically focused on allegations of managing illegal gold transfers and the possibility of possessing assets disproportionate to known sources of income.

The Court found that the Lokpal had sufficiently recorded its satisfaction regarding the existence of a prima facie case as required by the Act.

Regarding the petitioner's apprehension of arrest, the Court noted the CBI's submission that no such order had been passed and that the investigation would proceed independently.

Consequently, the Court found no procedural or substantive illegality in the Lokpal invoking its statutory powers to direct a time-bound investigation.

The Court held that there were no valid grounds to interfere with the directing of an investigation by an independent agency in light of the allegations.

The Court also rejected the petitioner’s prayer for protection from coercive action at this stage, noting the CBI's assurance that the investigation would follow the law.

The writ petition was disposed of without costs.