Lokpal must record cogent reasons for directing investigation against public servants exonerated in preliminary inquiry.

The Petitioner, a Senior Intelligence Officer at the Directorate of Revenue Intelligence (DRI), was part of an investigation into a smuggling syndicate allegedly masterminded by Respondent No. 5

In September 2024, Respondent No. 5 filed a complaint before the Lokpal (Respondent No. 1) alleging corruption and misconduct against the Petitioner and certain Kolkata customs officials

Pursuant to Section 20(1) of the Lokpal and Lokayuktas Act, 2013 ("the Act"), the Lokpal directed a preliminary inquiry by the CBI

The CBI’s report dated 11.12.2024 found no material against the Petitioner, a finding concurred with by the Director General of Vigilance (DGoV) and the Union Finance Minister as the Competent Authority

Despite this, the Lokpal issued a show-cause notice and subsequently passed the impugned order dated 24.07.2025, directing a full CBI investigation under Section 20(3)(a) of the Act against the Petitioner, citing "counter allegations supported with verifiable facts"

The Petitioner challenged this order via a writ of certiorari

1. Whether the Lokpal can exercise its discretion under Section 20(3) of the Act to direct a CBI investigation without recording specific reasons or identifying material that contradicts a favorable preliminary inquiry report

2. Whether an order passed by a statutory authority like the Lokpal is legally sustainable if it lacks clear and cogent reasoning for its prima facie satisfaction

Section 20 of the Lokpal and Lokayuktas Act, 2013, which mandates a structured process of preliminary inquiry, comments from competent authorities, and a reasoned prima facie satisfaction before directing an investigation

the principle that quasi-judicial and administrative authorities must record clear and explicit reasons for their decisions, as established in The Siemens Engineering & Manufacturing Co. of India Ltd. v. The Union of India and S.N. Mukherjee v. Union of India

per Mohinder Singh Gill v. The Chief Election Commissioner, the validity of a statutory order must be judged solely by the reasons mentioned therein and cannot be supplemented by fresh explanations later

The Court observed that the statutory scheme of Section 20 is not a procedural formality but a mandatory requirement ensuring that investigations are not launched based on mere allegations

In this case, the CBI, DGoV, and the Ministry of Finance had all exonerated the Petitioner

The Court reasoned that since the statutory record favored the Petitioner, the Lokpal was legally obligated to articulate specific reasons, material, or infirmities in the preliminary report to justify a departure from those findings

The impugned order failed to identify which "verifiable facts" supported the allegations or how they overcame the exculpatory findings of the CBI

The Court found that issuing notices and directing investigations mechanically, without discussing the specific role of the official or applying mind to the record, constitutes an arbitrary and whimsical exercise of power

The Court answered that the Lokpal cannot direct an investigation in an arbitrary manner when the preliminary inquiry report finds no material against the public servant

Consequently, the writ petition was allowed, and the impugned order dated 24.07.2025, the order dated 21.05.2025, and the notice dated 23.05.2025 were quashed insofar as they related to the Petitioner