Kerala HC Directs SFIO to Complete Popular Nidhi Fraud Investigation Within Three Months, Closes Follow-Up Petition After Criminal Complaints Filed
The Kerala High Court, in two successive writ petitions by a minority shareholders' welfare association, pushed the Serious Fraud Investigation Office to conclude its Popular Finance Group fraud inquiry and then closed the matter once criminal complaints were filed before the Additional Sessions Court, Ernakulam.
Two writ petitions filed by the MRPN Minority Shareholder Customers Welfare Association, Thiruvananthapuram, trace the arc of a fraud investigation that moved from stalled inquiry to criminal prosecution. In the first, decided on 3 June 2025, Justice P.V. Kunhikrishnan, sitting singly, directed the Serious Fraud Investigation Office (SFIO) to complete its investigation into M/s Mary Rani Popular Nidhi Ltd and the broader Popular Finance Group within three months. In the second, decided on 23 February 2026, Justice Viju Abraham, sitting singly, closed the matter after the Deputy Solicitor General of India confirmed that criminal complaints had already been filed before the Additional Sessions Court, Ernakulam, and that winding-up proceedings were also underway.
The Association's Grievance and the Government Order Behind It
The petitioner association, registered as TVM/TC/131/2021 and represented by its President Subramanian Potty, aged 77, approached the court in WP(C) No. 39488 of 2024. Its principal prayer was for a writ of mandamus directing the SFIO, the first respondent, to complete its investigation against M/s Mary Rani Popular Nidhi Ltd, the fourth respondent, in accordance with a specific government order.
That government order, produced as Exhibit P2, is G.O. No. 03/324/2020/CL-II(DGCOA)(SR) dated 7 January 2021, issued by the Ministry of Corporate Affairs. It handed over the investigation of alleged fraud against the fourth respondent and other group companies of Popular Finance to the SFIO. The association also sought a direction to dispose of a representation it had submitted to the SFIO on 5 January 2024, produced as Exhibit P3.
The respondents in the first petition were the Director, SFIO, New Delhi; the Ministry of Corporate Affairs; the Registrar of Companies, Kerala; and M/s Mary Rani Popular Nidhi Ltd, Pathanamthitta. Senior Panel Counsel Smt. Mini Gopinath appeared for the second respondent.
What the Ministry's Statement Revealed
Justice Kunhikrishnan directed the Central Government Counsel to file a statement based on instructions. The Ministry of Corporate Affairs, through its senior panel counsel, filed a statement whose relevant portion the court extracted in its judgment.
The statement disclosed two things. First, the investigation had revealed that the Popular Finance Group had “induced the gullible depositors and collected unauthorized deposits from the public at large” and that several violations of the Companies Act, 2013 and the LLP Act, 2008 had been committed by companies and LLPs within the group. Second, the investigation was described as being “at an advanced stage” and, upon completion, a consolidated investigation report would be submitted to the Central Government under the Companies Act, 2013 for further instructions.
The court took the Ministry at its word. Since the investigation was already at an advanced stage and a consolidated report was imminent, Justice Kunhikrishnan held that the writ petition need not be retained. The court disposed of the petition with a single operative direction: the SFIO was to complete the investigation as expeditiously as possible, and in any event within three months from the date of receipt of a certified copy of the judgment.
The Follow-Up Petition and Its Closure
The association returned to the High Court in WP(C) No. 555 of 2026, this time before Justice Viju Abraham. The petitioner's grievance in the second round was that no further proceedings had been initiated based on the final investigation report submitted by the SFIO.
The respondents in this petition were the Union of India, represented by the Secretary, Ministry of Corporate Affairs; the Registrar of Companies, Ernakulam; and the SFIO. The Deputy Solicitor General of India, Adv. O.M. Shalina, appeared for the respondents.
On instructions, the Deputy Solicitor General informed the court that criminal complaints had already been preferred before the Additional Sessions Court, Ernakulam. She also submitted that proceedings for winding up of the company had been initiated and that those proceedings might require another four weeks to complete.
Recording that submission, Justice Viju Abraham closed the writ petition on 23 February 2026.
Exhibits and Procedural Chain
The exhibits filed in the second petition illuminate the procedural chain. Exhibit P1 is the original government order dated 7 January 2021 that assigned the investigation to the SFIO. Exhibit P2 is a certified copy of Justice Kunhikrishnan's judgment dated 3 June 2025 in WP(C) No. 39488 of 2024. Exhibit P3 is a copy of an order dated 4 August 2025 in WP(C) No. 28019 of 2020, also passed by the Kerala High Court, though the digest does not detail its contents.
In the first petition, the petitioner's exhibits included the association's registration certificate dated 2 December 2021, the government order handing over the investigation, and the representation submitted to the SFIO on 5 January 2024.
Outcome
In WP(C) No. 39488 of 2024, decided on 3 June 2025, Justice P.V. Kunhikrishnan disposed of the petition directing the SFIO to complete the investigation against M/s Mary Rani Popular Nidhi Ltd and the Popular Finance Group within three months from the date of receipt of a certified copy of the judgment.
In WP(C) No. 555 of 2026, decided on 23 February 2026, Justice Viju Abraham closed the petition after recording the submission of the Deputy Solicitor General that criminal complaints had been filed before the Additional Sessions Court, Ernakulam, and that winding-up proceedings had been initiated against the company.