Delhi High Court rejects NGO's plea for material used by SFIO in probe against Reliance companies

The Delhi High Court has rejected a plea filed by Mandke Foundation, an NGO in which Tina Ambani is a director, seeking disclosure of material forming the basis of an investigation by the Serious Fraud Investigation Office (SFIO) in connection with Anil Ambani's Reliance Home Finance Limited, Reliance Communications Limited and other companies.

In the judgment delivered on July 29, Justice Swarana Kanta Sharma rejected the plea, stating that during the preliminary stage of SFIO investigation, there is no right to seek disclosure of material forming basis for investigation.

"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,” the Court stated.

Mandke Foundation is a charitable institution that runs the Kokilaben Dhirubhai Ambani Hospital at Mumbai. The SFIO issued a notice to the Foundation in April 2026 in connection with its investigation into the affairs of Anil Ambani's Reliance companies.

The notice stated that as per its preliminary investigation, the Foundation had directly or indirectly entered into financial transactions with the said Reliance companies.

Accordingly, the SFIO directed the Foundation to furnish certain information such as its bank account statements and financial records during the period between 2008-09 to 2025-26 and its dealings with other companies.

The foundation replied to the SFIO notice in June, expressing willingness to cooperate with the investigation. For this purpose, it requested the SFIO to first provide the Ministry of Corporate Affairs (MCA) orders on the basis of which the investigation was initiated. It also sought six weeks’ time from SFIO to furnish the records since the information sought was voluminous.

However, on July 20, the SFIO issued summons to directors Tina Ambani and her son and former director Jai Anshul Anil Ambani. The Foundation then moved the High Court seeking directions to the SFIO to provide the MCA orders and other material forming the basis of the investigation against it.

The Court observed that the SFIO’s notice provided sufficient context for the investigation. It stated that the Foundation was not left completely unaware of the nature or purpose of the information sought by SFIO.

It also noted that the Foundation has still not furnished the information sought by SFIO pertaining to the investigation into the Reliance companies.

The Central government contended that the MCA orders contain sensitive information related to the ongoing investigation and that its disclosure would prejudice the prone and connected proceedings concerning the Reliance companies pending before the Bombay High Court.

The Court agreed with the submissions, 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."

Senior Advocate Rajiv Nayar with Advocates Arshdeep Singh Khurana, Neeha Nagpal, Sulakshan, Vishvendra Tomar, Arjun Singh, Tannavi Sharma, Simran Khurana, Prabhav Bahuguna, Shreyas Maheshwari and Naman Maheshwari appeared for the NGO. 

Additional Solicitor General (ASG) Chetan Sharma and Central Government Standing Counsel Nidhi Raman and Kamlendra Mishra along with Advocates Krishna Pandey, Vinod Kumar, Shivam, Akash Mishra, Arnav Mittal, Amit Gupta and Subhash Sharma appeared for the Central government and SFIO.

[Read Judgment]