2026 Supreme(Online)(Tel) 18266

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Nagesh Bheemapaka, J
Vivimed Labs Limited – Appellant
Versus
Central Bureau of Investigation – Respondent
WRIT PETITION No. 1843 OF 2026

An interim order suspending an administrative classification of a bank account as 'fraud' does not preclude or invalidate independent criminal investigations into cognizable offences, as administrative and criminal proceedings operate in separate legal spheres governed by distinct statutory frameworks.

Headnote:(A) Indian Penal Code, 1860 - Sections 120-B, 420, 468, 471 and 477A - Prevention of Corruption Act, 1988 - Section 13(1)(d) and 13(2) - Bharatiya Nagarik Suraksha Sanhita, 2023 - Sections 96 and 185 - Delhi Special Police Establishment Act, 1946 - Section 6 - Administrative fraud classification vs. Criminal investigation - Economic offences regarding diversion of public funds - Interim order suspending administrative classification of an account as a specific category does not operate as a blanket embargo against statutory criminal investigation into cognizable offences. (Paras 6, 13, 14, 20, 21)

(B) Fundamental Rights - Articles 14, 19(1)(g) and 21 - Scope of judicial interference - Extraordinary jurisdiction of High Court under Article 226 - Not to be invoked to stifle legitimate criminal investigation into serious economic offences or to preempt statutory investigative powers during nascent stages. (Paras 21, 38, 39)

Facts of the case:
The petitioners challenged the search and seizure operations conducted by the investigative agency, asserting that such actions were illegal because they were based on an account classification that had been suspended by a prior interim order of the Court. The investigative agency maintained that the criminal FIR and subsequent searches were independent statutory actions based on allegations of cheating, forgery, and diversion of public funds, initiated via a formal complaint and authorized by judicial warrants.

Findings of Court:
The Court held that administrative proceedings under banking regulations and criminal investigations under penal laws operate in distinct spheres. The suspension of an administrative classification does not automatically invalidate or nullify criminal proceedings for cognizable offences. The investigative agency acted within its statutory authority under valid judicial warrants, and the interim order in the earlier writ petition did not specifically restrain the criminal investigation process.

Issues: Whether an interim order suspending the administrative classification of a loan account as a 'fraud' account creates a legal interdiction against separate criminal investigative proceedings, including search and seizure operations conducted under the provisions of the criminal procedure code.

Ratio Decidendi: Criminal proceedings into cognizable offences, particularly those involving public funds and economic fraud, are independent of administrative regulatory actions. An FIR and subsequent investigation constitute an exercise of statutory power that cannot be suppressed or invalidated merely because an underlying administrative action—which may have provided the initial information—is stayed on technical or procedural grounds. The Court cannot exercise its discretionary jurisdiction to stifle investigations into grave economic offences in the absence of manifest abuse of process.

Result: Writ Petition dismissed.