Investigation of FIR against ED officers transferred to CBI due to potential institutional bias and high-profile ramifications.

The petitioners, officials of the Enforcement Directorate (ED) Ranchi, were investigating high-profile money laundering cases involving senior state bureaucrats and politicians.

Respondent No. 5 (Santosh Kumar), an accused in a ₹23-crore siphoning scam, appeared at the ED office on 12.01.2026 without a summons.

The petitioners allege that during interaction, Kumar became agitated and self-inflicted a minor scalp injury using a glass water jug, a fact purportedly recorded by a Medical Officer at Sadar Hospital.

Conversely, Kumar lodged an FIR (Airport P.S. Case No. 05/2026) alleging custodial torture and attempt to murder.

Following the FIR, State police arrived at the ED office in the early morning of 15.01.2026, treating it as a crime scene without prior notice.

The petitioners moved the High Court seeking quashing of the FIR or, alternatively, transfer of the probe to the CBI.

1. Whether the presiding judge should recuse himself based on State objections regarding the judicial roster.

2. Whether the FIR against the ED officials should be quashed under the parameters of *State of Haryana v. Bhajan Lal*.

3. Whether the circumstances justify transferring the investigation from the State Police to the Central Bureau of Investigation (CBI).

The court primarily applied Section 67 of the Prevention of Money-Laundering Act (PMLA), which protects government officials acting in "good faith".

It relied on *State of Haryana v. Bhajan Lal* regarding the criteria for quashing an FIR.

It relied on *Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra* regarding judicial restraint during investigations.

For the transfer of investigation, it applied the "exceptional circumstances" doctrine established in *State of West Bengal v. Committee for Protection of Democratic Rights (CPDR)*, which allows Constitutional Courts to direct a CBI probe to maintain public confidence and ensure impartiality.

The court also referenced *Indore Development Authority v. Manohar Lal* to reject forced recusal.

The Court first addressed the roster objection, noting the notified roster explicitly included Criminal Writs relating to the Delhi Police Establishment Act/CBI, thus affirming its jurisdiction.

On the merits, the Court declined to quash the FIR at the threshold, noting that allegations of assault require investigation and do not meet the *Bhajan Lal* "no offence disclosed" criteria.

However, the Court expressed grave concern over the "haste" and "manner" in which the Jharkhand Police treated the ED office as a crime scene without mandatory notice under Section 35(3) of the BNSS.

It noted that the petitioners were presiding over sensitive cases involving the State’s political high-ups, creating a plausible inference of institutional bias or interference by the State machinery.

The discrepancies between the hospital’s initial "self-inflicted" report and the subsequent FIR, coupled with the "weaponization" of allegations by an accused (Kumar) who had previously used similar tactics against State police, necessitated an independent probe to instill public confidence.

It refused to quash the FIR (Airport P.S. Case No. 05 of 2026) but allowed the prayer to transfer the investigation.

The Court held that "exceptional circumstances" existed due to the conflict between a Central Agency and State machinery in a high-stakes political environment.

The Court ordered the Officer-in-Charge of Airport P.S. to forthwith hand over all case documents to the CBI, and directed the Director of CBI to register and investigate the case in accordance with law.

Intervention by the State Police was stayed.