Supreme Court Holds That Anti-Corruption Bureau FIRs Registered by Notified ACB Offices Remain Valid Post Andhra Pradesh Reorganisation and Cannot Be Quashed on Hyper-Technical Jurisdictional Grounds

Case Name: The Joint Director (Rayalaseema), Anti-Corruption Bureau, A.P. & Anr. v. Dayam Peda Ranga Rao & Ors.
Citation: 2026 INSC 37
Date of Judgment/Order: 08 January 2026
Bench: Justice M.M. Sundresh and Justice Satish Chandra Sharma

eld: The Supreme Court held that FIRs registered by the Anti-Corruption Bureau, Andhra Pradesh, including by the Office of the Joint Director, Central Investigation Unit, are not without jurisdiction merely because of alleged absence or delay in issuance of a fresh notification under Section 2(s) of the Code of Criminal Procedure after State bifurcation, as existing Government Orders and notifications declaring ACB offices as police stations continued to operate by virtue of the Andhra Pradesh Reorganisation Act, 2014.

Summary: The appeals arose after the Andhra Pradesh High Court quashed multiple FIRs registered by the Anti-Corruption Bureau for offences under the Prevention of Corruption Act, holding that the ACB office at Vijayawada was not a duly notified police station under Section 2(s) CrPC. The Supreme Court undertook an extensive analysis of Sections 2(s) and 2(o) CrPC, G.O.Ms. No. 268 dated 12.09.2003 declaring ACB offices as police stations, the Andhra Pradesh Reorganisation Act, 2014, and subsequent Government circulars and clarificatory orders. Relying on settled principles governing State reorganisation and continuity of laws, the Court held that notifications and orders having the force of law prior to bifurcation continued to apply unless altered or repealed, and that a hyper-technical approach resulting in termination of corruption investigations defeated both statutory intent and public interest.

Decision: The appeals were allowed, the impugned judgment of the Andhra Pradesh High Court quashing the FIRs was set aside, the validity of the FIRs and ongoing investigations was restored, liberty was granted to the investigating agency to proceed in accordance with law without taking coercive steps during investigation, a timeline of six months was fixed for filing final reports, and all pending applications were disposed of.