Constitutional and Administrative Basis

Under Articles 154 and 162 of the Constitution of India, the executive power of the State extends to matters within the State's legislative competence. “Public Order” and “Police” are Entries 1 and 2 respectively of List II of the Seventh Schedule.

The State therefore possesses the constitutional and administrative competence to organise, strengthen and appropriately supervise its police investigation machinery, subject always to law and judicial control.

Articles 14 and 21 additionally underscore the constitutional importance of fair, non-arbitrary and effective State action where citizens' life, liberty and legal rights are seriously affected.

Modern Mega Financial Crimes Require Specialised Investigation

The nature of modern financial crime has changed substantially. A conventional criminal investigation may concern a limited number of accused persons, witnesses, documents and transactions.

A mega financial crime may involve thousands of investors, hundreds of bank accounts, multiple corporate entities, directors and intermediaries, properties spread across districts and States, electronic communications, mobile phones, computers, accounting systems, registration records, suspected diversion of funds, subsequent alienations, civil proceedings, company proceedings and repeated criminal and constitutional litigation.

The difficulty is compounded by the fact that persons accused in very high-value financial offences may possess substantial financial resources and may engage multiple advocates and professional advisers to challenge notices, attachment proceedings, searches, seizures, summons, custody, property proceedings and other investigative steps before different judicial forums.

In such circumstances, even a sincere Investigating Officer can become overwhelmed. He or she must understand what the victims say, what the accused say, what the bank records establish, how money moved, what properties were purchased, in whose names they stand, whether third-party interests are genuine, what electronic evidence exists, which Court orders govern the investigation and which statutory procedure must be followed.

Investigation Must Survive Transfers of Officers

The problem becomes more acute because the same ACP/DCP and investigating teams are required to deal with several unrelated economic-offence files.

Each mega case requires sustained study. Frequent administrative transfers then create an additional discontinuity.

An officer who has spent several months understanding thousands of pages of material, the conduct of the parties, the money trail and the history of litigation may be transferred, and the succeeding officer effectively has to restart the learning process.

Where an ACP/DCP/Investigating Officer has substantially investigated a notified or identified mega financial crime, transfer from the concerned post should not automatically terminate that officer's responsibility for the case.

Subject to administrative feasibility and the decision of the competent Government/police authority, such officer may continue as a Case Continuity Officer / Additional Charge / Special Investigation Officer for that particular investigation until defined milestones are completed.

• Completion of major asset tracing.
• Filing of final or supplementary reports.
• Completion of attachment documentation.
• Effective handover certified by a senior supervisory officer.
• Reasonable transition assistance to the succeeding officer.

Mandatory Digital Case Handover

A mandatory detailed digital handover should record:

• Pending witnesses and accused persons.
• Bank accounts and financial transactions.
• Identified and suspected properties.
• Pending forensic reports.
• Court proceedings and attachment status.
• Pending notices.
• Existing legal restrictions and Court directions.
• Suspected additional assets.
• Next investigative steps.

Permanent Senior-Level Supervision for Mega Financial Crimes

VRPT respectfully submits that a mega financial crime should not remain dependent substantially upon a single DCP-level supervisory structure.

We therefore request consideration of a permanent senior hierarchy in CCS/EOW.

DFI CASE – A Practical Example of Why the Reform Is Necessary

Crime No.358/2023 itself illustrates the magnitude involved.

The material placed before the Hon'ble High Court records the prosecution case that DFI/group entities allegedly collected huge amounts from thousands of victims, many of them senior citizens, through high-return schemes, debentures, preference shares and plot allotments.

The competent authority contended that more than 30 companies were floated and more than ₹500 crore was mobilised.

Government Attachment Orders

• G.O.Rt.No.473 dated 20-06-2024
• G.O.Rt.No.474 dated 20-06-2024
• G.O.Rt.No.541 dated 05-07-2024
• G.O.Rt.No.542 dated 05-07-2024
• G.O.Rt.No.561 dated 08-07-2024
• G.O.Rt.No.665 dated 12-08-2024
• G.O.Rt.No.258 dated 22-03-2025
• G.O.Rt.No.259 dated 22-03-2025

These Government Orders subsequently formed part of the litigation before the Hon'ble High Court.

Property Network Reflected in Material Supplied to VRPT

• Approximately 3,005 sq. yards hospital site at Bagh Amberpet.
• Approximately Ac.17.46 cents at Narsingabilli, Kasimkota.
• Properties at Mustabada / Vedurupavuluru.
• Approximately Ac.29.31 guntas at Kothur / Midgil.
• Approximately Ac.351-15 guntas at Ananthasagar, Mallaram, Chowdaram and Cherlankireddipalli.
• Approximately Ac.62.23 guntas at Dumala / Akkapalli, Yellareddypet.
• Approximately 31,253 sq. yards at Mylardevpally / Rajendranagar.

Litigation History

The Sessions Judge/Special Judge proceedings culminated in orders dated 29-08-2025 concerning the attachments.

Thereafter, CRLA Nos.1040, 1041, 1042, 1043, 1044, 1045, 1046 and 1047 of 2025 came before the Hon'ble High Court.

The judgment identifies the appeals as arising from the 29-08-2025 Special Court orders and identifies the Competent Authority as the DCP, CCS, DD, Hyderabad.

The available High Court case material records stay applications and additional-material applications against the Special Court's attachment orders.

The batch of appeals was ultimately disposed of/dismissed on 05-05-2026.

The matter did not end there. In Crl.A.No.1182/2025, M/s Essenn Infra Township Pvt. Ltd. separately challenged the order in Crl.M.P.No.205/2024 arising out of the same Crime No.358/2023.

The record itself notes that the CCS investigation against DFI Ventures/group companies was still pending.

Separately, the NCLT Hyderabad Bench-II in Company Application No.04/71/HDB/2025, Kameswara Rao Mylavarapu v. DFI Nirmaan Private Limited pronounced its order on 06-05-2026, allowing the petition concerning redemption of debentures.

VRPT High Court Proceedings

VRPT itself has approached the Hon'ble High Court in WP No.17816/2026 seeking effective action regarding asset identification, tracing, seizure/attachment, bank accounts, investments, alleged proceeds, property transactions, electronic records and eventual recovery.

The prayer specifically refers to Registered Sale Deed Document No.853 of 2025 dated 10-12-2025 at Bejjanki and seeks investigation concerning alleged concealment or alienation during pendency of proceedings.

The petition also seeks Government-supervised auction/recovery measures and records VRPT's claim that it is assisting with statements, records and evidence for more than 1,198 victims.

The Present Legal Framework Already Recognises the Need for Rapid Asset Protection

Section 3 of the Telangana Protection of Depositors of Financial Establishments Act, 1999 expressly empowers the Government, where statutory conditions are satisfied, to pass ad-interim attachment orders over money/property procured from deposits and, where those assets are unavailable or insufficient, over other property of the financial establishment/promoter/manager/member as contemplated by the Act.

Section 4 provides for appointment of the Competent Authority and requires an application to the Special Court for making the ad-interim attachment absolute.

BNSS, 2023 – Relevant Investigative Mechanisms

In serious white-collar cases where the statutory prerequisites for immediate search or seizure exist, there should therefore be no avoidable advance disclosure that defeats the purpose of lawful investigative action.

• Mobile phones.
• Computers.
• Servers.
• Books of account.
• Financial records.
• Property records.
• Relevant electronic material.

Such material should be preserved at the earliest lawful stage, following applicable BNSS safeguards, judicial requirements and binding Court orders.

CCS Needs Its Own Permanent Legal and Financial Intelligence Capacity

A major weakness in complicated investigations can arise when the investigating officer must simultaneously investigate the offence and repeatedly prepare responses to sophisticated litigation.

For identified mega financial crimes, CCS/EOW should therefore have a permanent Financial Crime Legal Monitoring Cell, preferably consisting of experienced prosecution/legal officers.

• Every bail order.
• Every interim order.
• Every writ petition.
• Every attachment challenge.
• Every third-party claim.
• Every statutory appeal.

A direction relating to one particular notice, person, property or coercive measure should not, through administrative over-caution, be misunderstood as freezing every lawful aspect of an investigation.

Equally, every binding judicial direction must be scrupulously respected.

Forensic Accounting and Asset Tracing Cell

A corresponding Forensic Accounting and Asset Tracing Cell should maintain the money trail:

Revenue, Registration, banking, ROC/company data and digital evidence should be integrated into one investigation matrix rather than remaining in separate files.

CCS–ED and Multi-Agency Coordination

Where material discovered in a CCS investigation discloses facts attracting the statutory jurisdiction of the Enforcement Directorate under the Prevention of Money-Laundering Act , the matter should not remain trapped in departmental compartments.

VRPT respectfully proposes a formal nodal mechanism for exchange of legally shareable information between CCS/EOW and ED and, wherever appropriate, the following agencies:

Section 66 of PMLA itself contains a statutory information-sharing framework and further provides for sharing information with the concerned agency where material indicates contravention of another law.

Our Request to the Government

In these circumstances, Victims Rights Protection Trust most respectfully requests the Government of Telangana, the Director General of Police and the Home Department to immediately examine and implement a special institutional framework for Mega Financial Crime Investigations within CCS/EOW.

1. Establish Addl. DGP-level overall supervision for identified Mega Financial Crime investigations.
2. Establish IGP-level investigation monitoring and inter-agency coordination.
3. Continue the existing DCP/ACP operational investigation structure beneath the senior supervisory hierarchy.
4. Create permanent Financial Forensics capability.
5. Create a dedicated Asset Tracing Cell.
6. Create a dedicated Digital Evidence / Digital Forensics Team.
7. Create a permanent Financial Crime Legal Monitoring Cell.
8. Introduce a formal Case Continuity Protocol.
9. Permit, wherever administratively appropriate, a transferred knowledgeable Investigating/Supervisory Officer to continue the identified case in additional-charge, advisory or special-investigation capacity until an effective handover or defined milestone is completed.
10. Make a detailed Digital Case Handover Report mandatory in notified mega cases.
11. Classify Mega Financial Crimes separately on objective parameters.
12. Conduct periodic Addl. DGP-level review of all identified Mega Financial Crime cases.
13. Record investigation progress, pending forensic work, property identification and attachment status.
14. Record Court restrictions, pending prosecution steps and victim-recovery position.
15. Establish formal lawful information-sharing and coordination mechanisms with ED and other competent statutory agencies.
16. Consider the DFI investigation as an immediate case study for the proposed senior-level review mechanism.

Objective Parameters for Mega Financial Crime Classification

• Number of victims.
• Monetary magnitude.
• Interstate ramifications.
• Number of entities involved.
• Number of bank accounts involved.
• Number and geographical spread of properties.
• Complexity of the money trail.
• Litigation burden.

The Issue Raised by VRPT Is Much Larger Than DFI

When alleged economic offenders have access to substantial financial resources, sophisticated transactions and prolonged litigation, the State's investigative capacity must be institutionally stronger, legally better prepared and continuously supervised.

A victim who has lost his or her life savings cannot be expected to understand:

MOST IMPORTANT PUBLIC-INTEREST REPRESENTATION

VRPT therefore respectfully submits that this representation may kindly be treated as a MOST IMPORTANT PUBLIC-INTEREST REPRESENTATION REQUIRING IMMEDIATE POLICY AND ADMINISTRATIVE CONSIDERATION, and that a high-level meeting under the Chief Secretary / DGP / Home Department may kindly be convened to examine the strengthening of CCS/EOW on the above lines.

We therefore request immediate consideration and implementation in the larger public interest.