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Supreme Court Directs ED and CBI to Expedite ₹73,006 Crore Reliance Group Probe

Case Law Details

TaxGuru Citation
2026 taxguru.in 17344
Case Name
EAS Sarma Vs Union of India & Ors. (Supreme Court of India)
Date of Judgement/Order
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EAS Sarma Vs Union of India & Ors. (Supreme Court of India)

Summary: The Supreme Court of India, in EAS Sarma Vs Union of India & Ors., reviewed the progress of investigations by the Directorate of Enforcement (ED) and the Central Bureau of Investigation (CBI) into alleged financial irregularities involving the Reliance Anil Ambani Group (RAAG). The matter came before a three-judge Bench comprising the Chief Justice of India, Justice Joymalya Bagchi and Justice Vipul M. Pancholi on 23 March 2026. Pursuant to the Court’s earlier order dated 4 February 2026, both investigating agencies submitted status reports detailing the progress of their investigations. The proceedings concerned allegations of substantial financial losses to banks and financial institutions, possible diversion of funds, irregular insolvency transactions and suspected involvement of public officials. The Court examined these reports while emphasising the necessity of independent, transparent and time-bound investigations.

The ED informed the Supreme Court that a Special Investigation Team (SIT) had been constituted on 12 February 2026 to investigate cases connected with RAAG. The SIT comprised an Additional Director, two Deputy Directors and four Assistant Directors/Investigating Officers of the ED, together with forensic analysts and two staff members from Bank of Baroda. Investigations and inquiries into eight cases had commenced, and certain documents had been seized. The ED also reported the discovery of a purported arrangement described as “Project Help”, under which insolvency proceedings were allegedly initiated deliberately through unrelated lenders. According to the ED’s report, funding for acquisitions under the Insolvency and Bankruptcy Code (IBC) was arranged through a group of eight non-banking financial companies. The report stated that claims aggregating approximately ₹2,983 crore were settled for ₹26 crore. These matters remained under investigation, and the Court did not make any final determination regarding the allegations.

The CBI submitted that seven cases were under active investigation, including inquiries into the possible involvement of public servants. Its report identified five recent cases bearing numbers RC-05(E)/2025, RC-07(E)/2025, RC-08(E)/2025, RC-01(E)/2026 and RC-02(E)/2026. In case RC-01(E)/2026, the alleged wrongful loss to the complainant bank was stated to be ₹2,223 crore. The report further indicated that the losses alleged in other cases also ran into several thousand crores, with aggregate claims of approximately ₹73,006 crore. The Supreme Court considered the scale of the reported allegations significant enough to require coordinated and sustained investigative efforts. However, it expressly refrained from expressing any opinion on the merits of the allegations.

The Supreme Court observed that senior officers of the investigating agencies should collaborate to uncover any irregularities, illegal activities or possible collusion and connivance involving public officials, particularly officials of financial institutions, in extending undue benefits to RAAG management. The Court stressed that both the ED and CBI must conduct their investigations fairly, independently, transparently and dispassionately, bringing them to their logical conclusion within a reasonable timeframe. The Solicitor General assured the Court that every effort would be made to uncover the truth and that an endeavour would be made to complete the investigations within four weeks. The Court recorded this assurance without making a final finding on the alleged wrongdoing.

A further issue arose concerning the ED’s difficulty in obtaining information from other investigating agencies, regulatory bodies and financial institutions. The Solicitor General referred to the ED’s second status report, which showed that certain requested information had not been received. The information included material sought from the CBI concerning ECIR/STF/26/2025 and income-tax returns, tax audit reports and financial profiling information sought from the Central Board of Direct Taxes (CBDT) relating to intermediary shell entities allegedly appearing in the money trail of diverted funds from road construction projects. The Supreme Court directed all concerned agencies, financial institutions and other persons to extend full cooperation to the ED and provide the necessary information promptly. It further directed that any reluctance, resistance or delay must be reported by the ED to the Court. The matter was listed for further hearing on 30 April 2026.

FULL TEXT OF THE ORDER OF SUPREME COURT OF INDIA

1. In deference to our order dated 04.02.2026, status reports have been filed by the Directorate of Enforcement (ED) and the Central Bureau of Investigation (CBI).

2. The ED in its report has pointed out that a Special Investigation Team (SIT) has been constituted on 12.02.2026 to investigate the cases connected to the Reliance Anil Ambani Group (RAAG). The SIT comprises an Additional Director, two Deputy Directors, and four Assistant Directors/Investigating Officers of the ED. Some forensic analysts and two staff members of the Bank of Baroda have also been taken as a part of the SIT. It is pointed out that investigations/inquiries into eight cases have commenced, and some documents have been seized. It is not necessary for us to refer to the nature of the documents that are said to have been seized. In addition, a purported ‘Project Help’ has been uncovered, whereunder insolvency proceedings were deliberately started through unrelated lenders. According to the report, all funding for IBC acquisitions was arranged through a group of eight NBFCs. It is noted that claims totalling approximately Rs. 2,983 crores were settled for Rs. 26 crores.

3. The status report filed by CBI claims that seven cases are under active investigation, in which the roles of certain public servants are also being investigated. The details of the five latest cases, being (i) RC-05(E)/2025, (ii) RC-07(E)/2025, (iii) RC-08(E)/2025, (iv) RC-01(E)/2026, and (v) RC-02(E)/2026, are also briefly outlined. Inter alia, it is indicated that in RC-01(E)/2026, the total alleged wrongful loss to the complainant bank amounts to Rs. 2,223 crores, while the losses in the other cases also come to several thousands of crores, totalling claims of approximately Rs. 73,006 crores.

4. Since the preliminary facts speak for themselves, it is a situation where senior officials of the investigating agencies must collaborate and make a strong effort to uncover any irregularities, illegal acts, or collusion and connivance of public officials, especially those in the financial institutions, if any, in granting undue benefits to the management of RAAG. While we do not express any opinion on the merits of the allegations, all that we wish to observe is that it is imperative upon the CBI and the ED to complete the investigation in a most dispassionate, fair, transparent, and independent manner and take the ongoing investigation to its logical conclusion in a time-bound manner.

5. Learned Solicitor General of India assures that no stone shall be left unturned in unearthing the truth and that an endeavour shall be made to complete the investigation within four weeks.

6. The learned Solicitor General, at this stage, has pointed out that the second status report filed by the ED refers to information requested by the ED from other law enforcement agencies, regulatory bodies, financial institutions, and other concerned authorities. It has been further indicated that the information sought from some agencies has, however, not been received by the ED. For reference, the relevant extract of the chart presented in the report is reproduced below:

S. No. Info Requested From Requested on Date Gist of Information Requested Whether Received
1 Central Bureau of Investigation 29.08.2025
21.10.2025
ECIR/STF/26/2025: Copies of statements, physical and digital seized material during CBI search in FIR No. RCBD1/2025/E/0005 No
xx xx xx xx
3 Central Board of Direct Taxes 09.10.2025 F. No. T-3/122/MBZO-I/2023: ITRs, tax audit report, 360 degree profiling from insight portal of DG, Investigation in respect of intermediary shell entities appearing in money trail of diversion of funds from road construction projects No

xx xx xx xx

7. It goes without saying that all the concerned agencies, financial institutions, or other persons shall extend their full cooperation to the ED and make the necessary information available in a timely fashion. In the event of any reluctance, resistance, or delay shown by them, the ED is directed to submit a report to this Court.

8. Post this matter on 30.04.2026.

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Author Info

CA Sandeep Kanoi
Qualification: Graduate, CA in Job / Business, DD
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 23,152

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