Andhra Pradesh High Court Blocks CBI Director’s Unauthorized Officer Appointment in Tirupati Laddu Probe

In November 2024, a political and legal row broke out when Andhra Pradesh Chief Minister N. Chandrababu Naidu publicly charged animal fat had been added to the making of Tirupati laddus under the regime of the earlier Congress-led administration. The issue soon gained a lot of attention as the offering is of great religious importance at the Tirumala Tirupati Devasthanams (TTD).

In the wake of the accusation, the State government formed a Special Investigation Team (SIT) to look into the matter. But to ensure impartiality, the Supreme Court stepped in and dissolved the initial SIT. The Court formed a new SIT that included two CBI officers, two State government officers, and one officer from the Food Safety and Standards Authority of India (FSSAI). The probe was to be conducted strictly under the CBI Director’s watch.

Kaduru Chinnappanna, one of the petitioners, moved a petition to the Andhra Pradesh High Court. He complained that the Director of the CBI had taken permission from the Additional Superintendent of Police (SP), Tirupati to seize charge of the investigation. This officer was originally a member of the State-formed SIT, which had been deconstituted by the Supreme Court earlier. The petitioner asserted that such delegation went against the express mandate of the Court.

Reason Behind the Directions

The Supreme Court’s intention in reconstituting the SIT was to create an independent and unbiased investigation team. Involving central as well as state officers, and putting the team under the direct control of the CBI Director, the Court tried to shield the investigation from any kind of bias or political pressure.

When the issue came up for hearing in the Andhra Pradesh High Court, it examined whether the choice of the CBI Director to include an officer from the previous, defunct SIT had undermined the impartiality and framework established by the highest court. The main issue was whether this action was a transgression of judicial powers.

Core Legal Arguments

The petitioner, who was represented by Advocate Uday Kumar Vampugadavala, contended that the presence of the Additional SP from Tirupati, who had previously served on the previous SIT, breached the unequivocal orders of the Supreme Court. He pleaded that the apex court had not sanctioned any departure from the mandated composition of the reconstituted SIT.

The High Court, presided over by Justice Harinath N, considered the legal precedence and concurred with the petitioner’s argument. The judge noted that the 10^th respondent (the Additional SP) being appointed as an investigating officer, while he was not included in the reconstituted SIT, violated the order of the Supreme Court. The Court added that such a move would “certainly overreach the directions of the Hon’ble Supreme Court of India.”

Judgment of the Andhra Pradesh High Court

The High Court ruled that the nomination of the Additional SP by the Director of CBI as unauthorised and violative of the instructions of the Supreme Court. The bench stated that no official other than the five-member SIT, so set up by the apex court, could participate in the probe. The Court stressed that obedience to the directions of the Supreme Court is not a matter of choice and that any action on the contrary is not permissible by law.

Consequently, the Court permitted the writ petition. It instructed the Director of the CBI to conduct the investigation solely in accordance with the parameters established by the Supreme Court.

Controversial Quote from the Judgment

“Inclusion of the 10^th respondent as investigating officer over and above the number of reconstituted SIT is not permissible and would certainly overreach the directions of the Hon’ble Supreme Court of India.”

“For the reasons above, the writ petition is granted ordering Respondent No.2 to carry out a free and fair inquiry by over-sighting the inquiry which is to be carried out by the reconstituted SIT in accordance with directions of the Hon’ble Supreme Court.”

Legal Implications and Analysis

This ruling asserts the doctrine that directions issued by the Supreme Court have to be obeyed to the letter, especially where they pertain to delicate investigations involving public faith and religious emotions. The case points out that discretionary power in investigation has to work within rigid legal constraints, and even top officials like the CBI Director cannot modify the composition or structure of a Court-directed SIT.

The judgment also confirms the boundaries of delegation in criminal investigations. The Director of the CBI, despite oversight being their responsibility, cannot allocate officers to the team over and above those specified or approved by the Supreme Court. Not only does this upset the Court’s equilibrium in the SIT’s composition, but it also impugns the impartiality of the process.

This case establishes an important precedent regarding judicial supervision of investigative agencies. Courts continue to exercise jurisdiction to set right any lapse from procedural protections, particularly in cases pertaining to religious bodies or charges of corruption. This decision will certainly serve as a warning bell for all law enforcement organizations to follow Court-prescribed guidelines scrupulously.

Conclusion

The State government had initially constituted its own SIT, which the Supreme Court later substituted with a specially framed team to avoid prejudice and remove influence. But when the CBI Director permitted an officer of the previous SIT to rejoin the investigation, it led to a legal challenge.

The Andhra Pradesh High Court intervened to assert the primacy of the directions of the Supreme Court and reaffirmed that investigative agencies cannot override judicial directions. The High Court judgment restored the original composition and supervision of the SIT as visualized by the top court.

Currently, the probe has to be conducted under the direct watch of the CBI Director, restricted to the five-member team as specified by the Supreme Court, without any addition of unauthorized officers. The verdict secures the probe’s integrity and sends a clear message on upholding constitutional discipline and procedural fidelity in high-profile probes.

Sources

1. The Indian Express, ‘CBI Breached SC Mandate by Naming Tirupati Officer in SIT, AP HC Rules’ (13 July 2025)

https://indianexpress.com/article/india/tirupati-laddu-cbi-delegation-supreme-court-order-9487321

• LiveLaw, ‘AP High Court: CBI Director’s Nomination of Officer Beyond Reconstituted SIT Is Illegal’ (12 July 2025)

https://www.livelaw.in/top-stories/ap-hc-on-tirupati-laddu-case-cbi-director-supreme-court-order-298211

• SCC Online, ‘Andhra Pradesh High Court: Delegation by CBI Director in Violation of Supreme Court Order’ (13 July 2025)

https://www.scconline.com/blog/post/2025/07/13/ap-hc-ruling-cbi-delegation-tirupati-laddu-case