High Court Dismisses NGO’s Plea for SFIO Investigation Basis
The Delhi High Court has dismissed a petition by Mandke Foundation, a non-governmental organization where Tina Ambani serves as a director. The NGO sought the disclosure of documents forming the basis of an investigation by the Serious Fraud Investigation Office (SFIO) into Anil Ambani’s Reliance Home Finance Limited, Reliance Communications Limited, and other associated entities. In a judgment rendered on July 29, Justice Swarana Kanta Sharma ruled against the plea, emphasizing that at the preliminary stage of an SFIO investigation, there is no entitlement to demand disclosure of the foundational materials.
“No enforceable right has been made out by the petitioner to seek disclosure of the MCA Orders and the underlying material at this preliminary stage of the investigation,” stated Justice Sharma in her decision.
SFIO Investigation and Mandke Foundation’s Response
Mandke Foundation, known for operating the Kokilaben Dhirubhai Ambani Hospital in Mumbai, received a notice from the SFIO in April 2026. The notice pertained to the SFIO’s investigation into financial transactions between the Foundation and the Reliance companies. The SFIO requested detailed information, including the Foundation’s bank statements and financial records from 2008-09 to 2025-26, as well as details of dealings with other companies.
Responding in June, the Foundation expressed its willingness to cooperate but requested the SFIO provide the Ministry of Corporate Affairs (MCA) orders that triggered the investigation. It also sought six weeks to gather the voluminous information requested. Despite this, the SFIO issued summons on July 20 to directors Tina Ambani and her son, Jai Anshul Anil Ambani, a former director.
Subsequently, the Foundation approached the Delhi High Court, seeking directives for the SFIO to disclose the MCA orders and other materials forming the basis for its investigation.
Court’s Rationale and Government’s Position
The Court observed that the SFIO’s notice sufficiently outlined the investigation’s context, and the Foundation was not entirely unaware of the investigation’s nature. The Court further noted that the Foundation had not yet provided the requested information related to the investigation into the Reliance companies.
The Central government argued that the MCA orders contained sensitive information, and their disclosure could prejudice ongoing and related proceedings concerning the Reliance companies at the Bombay High Court. The Court concurred with this argument, stating, “At this stage, this Court finds no reason to disregard the said contention, since the investigation is admittedly continuing and disclosure of the orders passed by MCA directing such investigation, together with the entire material forming the basis thereof, at this stage, may prejudice the course of the investigation extending beyond the present petitioner alone.”
Legal Representation
Senior Advocate Rajiv Nayar, along with Advocates Arshdeep Singh Khurana, Neeha Nagpal, Sulakshan, Vishvendra Tomar, Arjun Singh, Tannavi Sharma, Simran Khurana, Prabhav Bahuguna, Shreyas Maheshwari, and Naman Maheshwari, represented the NGO.
Additional Solicitor General (ASG) Chetan Sharma, together with Central Government Standing Counsel Nidhi Raman and Kamlendra Mishra and Advocates Krishna Pandey, Vinod Kumar, Shivam, Akash Mishra, Arnav Mittal, Amit Gupta, and Subhash Sharma, appeared for the Central government and SFIO.
