Power of inspector to conduct investigation into affairs of related companies, etc
Section 219 of the Companies Act, 2013 deals with power of inspector to conduct investigation into affairs of related companies, etc. If an inspector appointed under section 210 or section 212 or section 213 to investigate into the affairs of a company considers it necessary for the purposes of the investigation, to investigate also the affairs of (a) any other body corporate which is, or has at any relevant time been the companys The Act came into force on 01 Apr 2014.
If an inspector appointed under section 210 or section 212 or section 213 to investigate into the affairs of a company considers it necessary for the purposes of the investigation, to investigate also the affairs of
(a) any other body corporate which is, or has at any relevant time been the companys subsidiary company or holding company, or a subsidiary company of its holding company;
(b) any other body corporate which is, or has at any relevant time been managed by any person as managing director or as manager, who is, or was, at the relevant time, the managing director or the manager of the company;
(c) any other body corporate whose Board of Directors comprises nominees of the company or is accustomed to act in accordance with the directions or instructions of the company or any of its directors; or
(d) any person who is or has at any relevant time been the companys managing director or manager or employee,
he shall, subject to the prior approval of the Central Government, investigate into and report on the affairs of the other body corporate or of the managing director or manager, in so far as he considers that the results of his investigation are relevant to the investigation of the affairs of the company for which he is appointed.
Section 219, The Companies Act, 2013 (Act 18 of 2013).
Cross-references
Extracted from the operative text of the enactments themselves. Every destination below exists in our corpus.
This section refers to
Related judgements & precedents
These are some judgments that construed this section, and hold precedence value. They hold authority on how to read, interpret and use this section.
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Serious Fraud Investigation Office vs Sahara Housing Investment Corporation Limited
Court's Decision & Legal Precedent
The prescribed period for investigation completion under Section 212(3) of the Companies Act 2013 is directory in nature and not mandatory. Expiry of the stipulated period does not terminate the investigation mandate. The investigation continues until final completion as contemplated by Section 212(12). High Courts should not pass blanket interim orders staying investigations and coercive proceedings at the interlocutory stage, as such orders may hamper investigations. The Central Government need not record detailed reasons when ordering an investigation under Section 212, as the purpose of investigation is to inquire into affairs and material emerges during the investigation process. Section 219(c) of the Companies Act 2013 authorizes investigation into companies whose Board comprises nominees of the principal company or which are accustomed to act under its directions, independent of subsidiary or holding company relationships.
On this section: Inspector's power to investigate related companies; clauses (a), (b), (c), and (d) define scope of related entities; investigation into six companies authorized under Section 219(c)
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Serious Fraud Investigation Office vs Sahara India Commercial Corporation LTD
Court's Decision & Legal Precedent
The procedural timeline prescribed in Section 212(3) of the Companies Act 2013 for submission of investigation report is directory and not mandatory in nature. An investigation mandate does not terminate upon expiry of the stipulated period but continues until completion of investigation and submission of final report. The Central Government is not required to furnish elaborate reasons when ordering investigation under Section 212 and Section 219 as the purpose of investigation is to conduct full enquiry into company affairs with material emerging during the investigation process. Section 219(c) of the Companies Act 2013 empowers investigation of body corporates whose Board of Directors comprises nominees of the company or which is accustomed to act in accordance with directions or instructions of the company or its directors. High Courts should exercise caution in passing blanket interim orders staying investigation proceedings as such orders hamper investigation at early stage.
On this section: Power of inspector to investigate related companies; clauses (a), (b), (c), and (d) provide different categories of related entities
The holding above is the ratio decidendi as extracted from the judgment by eCourts India, reproduced unaltered — it is a rendering of the court's reasoning, not a substitute for its words. Read the order itself before relying on it.
Judgments citing this section
These may be obiter dicta or a precedent, for you to study. These are the judgments where this section is quoted.
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… The said investigation shall be carried out by officers of the as nominated by Director, SFIO. - 5. That the Inspector(s) so appointed shall exercise all the powers available to him under section 217 of the Companies Act, 2013 including power conferred under section 219 of the Companies Act, 2013 after seeking approval of Central Government where ever required. The inspector(s) complete the investigation and submit the report to the Central Government within a period of 03 (three) Months. - 6. This order is issued for and on behalf of the Central Government. Sd/- (V.R. Sheth) …
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… ExtP3 is the order dated 25-09-2012 whereby the court below directed the following : > "There is already an order from this court in I.A No.69/2011, restraining the 1 st respondent from convening Annual General Body Meeting without complying the formalities u/s 219 of the Companies Act until disposal of this suit. I hereby bringing the same to the notice of the 1 st respondent again. Considering the request of the 1 st defendant's counsel the case is reopened for further hearing and in the meantime the 1 st respondent is directed to maintain status quo. For further …
Questions about Section 219
What have the courts held on Section 219 of the Companies Act?
Serious Fraud Investigation Office vs Sahara Housing Investment Corporation Limited (26 May 2022) is the leading judgment on this section among those set out below: Inspector's power to investigate related companies; clauses (a), (b), (c), and (d) define scope of related entities; investigation into six companies authorized under Section 219(c). Another 1 judgment on this section is set out below, all of them from the Supreme Court.
How do I find court cases under Section 219 of the Companies Act?
In judgments and charge sheets this section is written several ways, and each form finds a different set of orders. These search the full text of every order eCourtsIndia holds, best matches first: Companies Act 219, section 219 Companies Act, section 219 of the Companies Act. Each opens the full list of orders on eCourtsIndia, where it can be narrowed by court, year and outcome. 2 reported judgments on this section are set out on this page, beginning with Serious Fraud Investigation Office vs Sahara Housing Investment Corporation Limited (26 May 2022).
What should I read with Section 219 of the Companies Act, and has it changed?
Its own text turns on section 210 (Investigation into affairs of company), section 212 (Investigation into affairs of company by Serious Fraud Investigation Office), section 213 (Investigation into company‘s affairs in other cases), so none of them can safely be read on its own. 2 other provisions in this corpus refer back to it.
When did Section 219 of the Companies Act come into force?
Section 219 of the Companies Act, cited as Companies Act 219, came into force on 01 Apr 2014, having been enacted on 29 Aug 2013. It is in force as at the date shown on this page.
Other sections of this Act
- 2. Definitions5089 words
- 143. Powers and duties of auditors and auditing standards1867 words
- 230. Power to compromise or make arrangements with creditors and members1432 words
- 232. Merger and amalgamation of companies1416 words
- 149. Company to have Board of Directors1403 words
- 217. Procedure, powers, etc., of inspectors1390 words
Source and method. Compiled from the enactments of Parliament and of the State legislatures as published on India Code, and republished together with commentary and other original matter under section 52(1)(q)(ii) of the Copyright Act, 1957. Structured, cross-referenced and maintained by eCourtsIndia. Text as in force on 14 Oct 2026. This page is not a substitute for legal advice.