New Delhi: The Supreme Court of India on Thursday revived a series of corruption cases in Andhra Pradesh, overturning a highly technical judgment of the Andhra Pradesh High Court that had quashed First Information Reports (FIRs) and terminated criminal proceedings under the Prevention of Corruption (PC) Act. The apex court described the high court’s approach as “nothing but a travesty of justice,” emphasizing that procedural formalities should not obstruct the course of legitimate investigations.

The bench, comprising Justices MM Sundresh and Satish Chandra Sharma, observed that the high court’s ruling left several investigations “nipped in the bud” while prematurely terminating criminal proceedings in other cases. The decision came in an appeal filed by the Joint Director of the Anti-Corruption Bureau (Rayalaseema), aggrieved by the Andhra Pradesh High Court’s 2025 order quashing cases registered with ACB, Vijayawada, on the ground that the office was not a “police station” under the Code of Criminal Procedure (CrPC).

Senior advocates Siddharth Luthra and Sidharth Agarwal represented the ACB, arguing that the high court had failed to account for the practical realities following the bifurcation of Andhra Pradesh in 2014.

Background

Prior to the bifurcation of the undivided Andhra Pradesh in 2014, the state government, in 2003, had designated the ACB, Hyderabad, as a police station, allowing several PC Act cases to be registered there. After the creation of Telangana, the Andhra Pradesh government in 2016 issued a notification transferring ACB operations to Vijayawada. A subsequent order in 2022 formally designated ACB, Vijayawada, as a police station, since Hyderabad no longer fell under Andhra Pradesh jurisdiction.

Despite these steps, the Andhra Pradesh High Court took a strictly technical view, ruling that the previous legal framework continued to apply even after the state bifurcation. Based on this reasoning, FIRs registered with ACB, Vijayawada, between 2016 and 2020 were quashed, halting ongoing investigations.

Supreme Court’s Observations

The Supreme Court strongly criticized this hyper-technical approach. The bench observed:

“In our considered view, the High Court has completely misdirected itself while interpreting the law. The High Court took undue pains to ensure that the FIRs are quashed.”

The apex court emphasized that once the Andhra Pradesh government issued a clarificatory notification in 2016, the jurisdiction of the ACB in Vijayawada was clear, and there was no basis to invalidate the FIRs.

“If, on a hyper-technical ground, the FIRs are quashed, the High Court is duty-bound to lay down the law with respect to the jurisdiction that otherwise exists,” the bench said.

Rejecting the high court’s reasoning, the Supreme Court stated that the requirement for a notification to be published in the official gazette under Section 2(s) of the CrPC was a matter of formality and should be understood in substance rather than strictly in technical terms. The bench held:

“The reasoning of the High Court—that a declaration by way of a notification must be published in the official gazette for due compliance with Section 2(s) of the CrPC, 1973—is, to say the least, unacceptable. One has to see the substance and due compliance in spirit.”

The apex court also rejected the notion that the 2022 government order designating ACB, Vijayawada, as a police station would not affect previously registered FIRs, calling the high court’s finding “totally untenable and against the basic canons of law.”

Key Directions

The Supreme Court set aside the Andhra Pradesh High Court judgment and restrained the high court from entertaining any further challenges to FIRs on this ground. However, it clarified that the accused retain all legal remedies to challenge chargesheets where investigations were complete, ensuring procedural fairness while safeguarding ongoing probes.

The apex court’s judgment reinforces the principle that technical formalities cannot obstruct the investigation of corruption cases and that the law must be interpreted in the light of its purpose rather than rigid procedural adherence.

Wider Implications

This ruling has significant implications for the handling of corruption cases across India. By reviving investigations previously derailed on technical grounds, the Supreme Court has underscored the need for courts to prioritize substance over procedural technicalities, particularly in cases involving offences under the Prevention of Corruption Act.

It also highlights the complexities arising from state bifurcations and administrative reorganizations, which can create confusion about the jurisdiction of investigative agencies. The Supreme Court’s clear assertion ensures that administrative clarifications by the state government carry weight and cannot be undermined by overly literal interpretations of the law.

Conclusion

The Supreme Court’s intervention sends a strong message that corruption cases must be allowed to proceed unhindered by hyper-technical interpretations and that investigative agencies must have the legal backing to pursue cases in accordance with government notifications and clarifications.

By reviving the Andhra Pradesh corruption cases, the apex court has reaffirmed the judiciary’s commitment to upholding the integrity of anti-corruption investigations, ensuring that procedural technicalities do not obstruct the pursuit of justice.