Vinay Aggarwal vs State of Haryana 2025: Supreme Court Case

Vinay Aggarwal vs State of Haryana 2025 gained attention for two main reasons. First it questioned the routine transfer of criminal investigations to the CBI without substantial evidence of bias or failure by the local police. Second, it highlighted the misuse of legal remedies under Section 482 CrPC. The decision of the Supreme Court reinforced principle that such extraordinary powers must be used with caution. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Vinay Aggarwal vs State of Haryana 2025 Introduction

Vinay Aggarwal vs State of Haryana (2025) is an important decision of the Supreme Court regarding the misuse of inherent powers under Section 482 of Criminal Procedure Code. The case centres around the alleged impersonation of an Intelligence Bureau officer and extortion of a businessman. The main issue was whether the Punjab and Haryana High Court rightly transferred the investigation to the Central Bureau of Investigation (CBI) at a preliminary stage.

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The case at hand centres around allegations of impersonation, criminal conspiracy and extortion, where the Appellant was accused of impersonating as an Intelligence Bureau officer to coerce a businessman into transferring large sums of money. The following are the facts of Vinay Aggarwal vs State of Haryana -

Background and Procedural History

The Supreme Court allowed permission to file the Special Leave Petition (SLP) and subsequently granted leave in the matter. The facts outlined here are primarily derived from the case which was treated as the lead case.

FIR Registered at Panchkula

The Appellant was named as an accused in First Information Report registered on 29th October, 2022 at Police Station Sector 20, Panchkula (Haryana). The FIR invoked provisions under Section 120B, Section 177, Section 406, Section 420, Section 467, Section 468, Section 471 and Section 506 of Indian Penal Code.

The FIR was filed based on a complaint by Jagbir Singh i.e., Respondent No. 3 who was a pharmaceutical businessman. He claimed that the Appellant impersonated an Inspector General (IG) of the Intelligence Bureau (IB) and coerced him to transfer Rs. 1.49 crore into the account of Appellant.

Allegations of Impersonation and Extortion

According to the complainant, the appellant threatened and pressured him to carry out business transactions with the associates of the Appellant including Dr. Komal Khanna (Co-accused). The complainant contended that undue pressure was exerted on his business to extort large sums of money.

Transfer of Investigation to CBI

The complainant filed a petition under Section 482 of Criminal Procedure Code before the Punjab and Haryana High Court and sought transfer of the investigation from the Haryana Police to the Central Bureau of Investigation (CBI). The High Court allowed the plea and directed that the investigation be handed over to the CBI. Aggrieved by this order, the Appellant approached the Supreme Court.

Prior FIR in Shimla

Before the Panchkula FIR, a similar FIR had been registered on 6th January, 2022 at P.S. CID-Bharari, Shimla. Although Jagbir Singh was not the complainant in that FIR, the Appellant contended that it was also instigated by him and involved similar charges of impersonation and extortion from industrialists.

Quashing of Shimla FIR by Himachal Pradesh High Court

The Appellant approached the Himachal Pradesh High Court under Section 482 of Criminal Procedure Code and sought to quash the Shimla FIR. The High Court concluded that the FIR was an abuse of the process of law and accordingly quashed it.

The following issues were addressed in Vinay Aggarwal vs State of Haryana 2025 -

• Whether the High Court was justified in transferring the investigation to the CBI under Section 482 of Criminal Procedure Code at the initial stage?
• The Supreme Court examined if the decision of the High Court to hand over the investigation to the Central Bureau of Investigation (CBI) was premature and legally sustainable?
• The Court in Vinay Aggarwal vs State of Haryana analysed the standard laid down by the Constitution Bench in State of West Bengal v. Committee for Protection of Democratic Rights?
• The Court examined whether unsubstantiated claims that police officials were acquainted with the accused could be a valid ground for CBI involvement?
• The Court addressed whether the CBI’s registration of a new FIR after the Supreme Court had stayed the High Court’s order constituted contempt of court.
• The case examined the limits of inherent powers of the High Court under Section 482 Criminal Procedure Code?

Vinay Aggarwal vs State of Haryana 2025 Legal Provisions

Section 482 of Criminal Procedure Code played an important role in Vinay Aggarwal vs State of Haryana. The following is analysis of this provision 

Section 482 of Criminal Procedure Code, 1973

Section 482 CrPC (Now Section 528 of Bharatiya Nagarik Suraksha Sanhita 2023) vests inherent powers in the High Court to make orders necessary to stop the abuse of the process of any court or to secure the ends of justice .

Vinay Aggarwal vs State of Haryana 2025 Judgment and Impact

On 2nd April, 2025 the 2-Judge Bench of the Supreme Court comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran in Vinay Aggarwal vs State of Haryana 2025 reviewed both First Information Report but did not agree with the arguments of the Appellant that the two - FIR which was quashed by Himachal Pradesh High Court and FIR which is now transferred to the CBI were of similar nature. The Supreme Court observed that although some facts may overlap, the two First Information Reports relate to different incidents and causes of action.

The Supreme Court found it difficult to understand why the complainant rushed to file a petition under Section 482 of Criminal Procedure Code before the High Court when the FIR had been registered only recently and the investigation was still at a preliminary stage.

The Court in Vinay Aggarwal vs State of Haryana 2025 condemned the petition filed by the complainant for being based on vague and unsubstantiated allegations such as the Appellant’s impersonation as an IB officer and being seen with Haryana police personnel. The complainant also contended that some police officials were familiar with the Appellant and might protect him, but failed to provide substantial evidence to support these claims.

The Supreme Court noted that the complainant himself admitted knowing the Appellant since 2019 due to business dealings. In case if the Appellant had impersonated an IPS officer, the Court found it implausible that the complainant remained unaware of the truth until October 2022. Hence, the Court held that the High Court should have been cautious and avoided handing over the case to the CBI.

The Supreme Court in Vinay Aggarwal vs State of Haryana also referred to the State of W.B. v. Committee for Protection of Democratic Rights (2010) where a Constitution Bench held that Constitutional Courts can order CBI investigations in exceptional circumstances. However, this power must be exercised sparingly and with caution.

Thus, the Supreme Court in Vinay Aggarwal vs State of Haryana set aside the order of Punjab and Haryana High Court and allowed the appeal.

Conclusion

In Vinay Aggarwal vs State of Haryana 2025 the Supreme Court allowed the appeal and set aside the order of Punjab and Haryana High Court of transferring the case to the CBI. The Court ruled that vague allegations and prior acquaintance with police officials cannot justify such a transfer. The Court highlighted that constitutional courts must use their powers sparingly only in rare and compelling cases.