Joint Director (Rayalaseema) Vs Dayam Peda Ranga Rao Etc. (Supreme Court of India)
Supreme Court: ACB Offices Are Valid Police Stations — Quashing of FIRs on Hyper-Technical Grounds Set Aside; Investigation Under PC Act to Proceed
The Supreme Court allowed the criminal appeals and set aside the judgment of the Andhra Pradesh High Court which had quashed multiple FIRs registered by the Anti-Corruption Bureau (ACB), Andhra Pradesh on the ground that the ACB, Central Investigation Unit, Vijayawada was not a duly notified “police station” under Section 2(s) CrPC.
The Court held that the High Court had adopted a hyper-technical and erroneous approach, ignoring the legal continuity of laws and notifications following the Andhra Pradesh Reorganisation Act, 2014. It ruled that:
- G.O.Ms. No. 268 dated 12.09.2003, which declared ACB offices as police stations, continued to operate as “law” even after bifurcation, by virtue of Sections 100–102 of the 2014 Act;
- No fresh or separate notification was required merely because the ACB office was relocated from Hyderabad to Vijayawada;
- The 2022 Government Order was only clarificatory, not creating new jurisdiction, and therefore did not involve retrospective operation;
- Quashing FIRs without identifying an alternative competent jurisdiction amounted to a travesty of justice and defeated the object of the Prevention of Corruption Act, 1988.
Relying on binding precedents including Balbir Singh, Swarn Rekha Cokes, Lafarge Dealers Association, and its recent decision in CBI v. A. Satish Kumar (2025), the Supreme Court reaffirmed that laws, notifications, and government orders having the force of law continue post-reorganisation unless expressly repealed or amended.
Directions issued:
