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Delhi HC Dismisses SFIO Investigation Writ for Lack of Territorial Jurisdiction

Case Law Details

TaxGuru Citation
2026 taxguru.in 12294
Case Name
Anil Laxminarayan Biyani Vs Union of India and Anr. (Delhi High Court)
Date of Judgement/Order
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Anil Laxminarayan Biyani Vs Union of India and Anr. (Delhi High Court)

Summary: The Delhi High Court dismissed the writ petition filed by Anil Laxminarayan Biyani challenging the Ministry of Corporate Affairs (MCA) order dated 31.10.2025 directing the Serious Fraud Investigation Office (SFIO) to investigate the affairs of Future Retail Limited (FRL) and Future Consumer Retail Private Limited (FCRPL). The petition was dismissed on the ground of territorial jurisdiction, with the Court holding that the High Court of Bombay was the appropriate and convenient forum. The Court expressly clarified that it had not examined the merits of the challenge or any other issue relating to the investigation.

FRL and FCRPL were incorporated in 2007. The judgment records the restructuring discussions concerning the Future Group’s HomeTown and FabFurnish businesses during 2016–2017 and the proposed demerger into Praxis Home Retail Private Limited. Amazon acquired a 49% stake in Future Coupons Private Limited in 2019. SEBI subsequently initiated proceedings concerning alleged insider trading in FRL shares during the period from 10.03.2017 to 20.04.2017. The SEBI order dated 03.02.2021 was challenged before the Securities Appellate Tribunal, which on 20.12.2023 quashed the SEBI order and exonerated the appellants, holding, inter alia, that the trading was not based on UPSI.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,678

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