### Parallel FIR involving Corporate Fraud transferred to SFIO for investigation as a supplementary complaint.

The Petitioner, a former MLC and Chancellor of Glocal University, sought the quashing of FIR Case Crime No. 421/2024 lodged under Sections 406, 420, 467, 468, 471, 120-B, and 506 of the IPC.

The Complainant alleged he was defrauded of INR 6,33,00,000/- transferred to M/s Enchant Infrastructure Pvt. Ltd. for a real estate development project that never commenced and saw its allotment cancelled.

Parallelly, the Serious Fraud Investigation Office (SFIO) had already investigated the Petitioner’s corporate network under Supreme Court directions, resulting in a pending complaint (No. 720/2017) involving the same shell companies.

The Petitioner contended the FIR was an impermissible second investigation into facts already covered by the SFIO.

The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which preserves the High Court's inherent power to prevent abuse of process and secure the ends of justice.

The Court relied on State of Haryana v. Bhajan Lal regarding the parameters for quashing an FIR.

The Court relied on SFIO v. Rahul Modi, which establishes that once an investigation is assigned to the SFIO under Section 212 of the Companies Act, 2013, other agencies are denuded of jurisdiction over those corporate offences.

The Court also noted Section 193(9) of the BNSS regarding the power to conduct "further investigation" even after a report is filed.

The Court found a "substantial congruence" between the SFIO complaint and the FIR, noting that the companies and many IPC sections (406, 420, 120-B) overlapped.

However, it observed a critical distinction: the specific transaction involving the Complainant’s INR 6.33 crore was not explicitly covered in the existing SFIO complaint.

Applying the Bhajan Lal standards, the Court determined that because the FIR disclosed a cognizable offence and a specific loss to a private individual, outright quashing would leave the victim remediless.

Conversely, allowing the State STF to continue a parallel inquiry into the same corporate "architecture" already seized by a specialized agency (SFIO) would lead to fragmentation and potentially conflicting findings.

To prevent abuse of process and ensure procedural integrity, it ordered the transfer of the investigation from the STF to the SFIO.

The SFIO was directed to treat the Complainant’s grievance as a "further investigation" under Section 193(9) of the BNSS and, if warranted, file a supplementary complaint before the Special Court.

The Court clarified that since the SFIO was already authorized to investigate the Petitioner by the Supreme Court, no fresh sanction from the Central Government was required.