Joint Director (Rayalaseema), ACB, A.P. v. Dayam Peda Ranga Rao 2026 INSC 37 - CrPC - Is It Necessary That Specific Place Has To Be Declared As A Police Station?

Note

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Code of Criminal Procedure 1973 - Section 2(s) - There need not be a specific place to be declared as a police station, as even a post being held by a police officer would constitute a police station- The definition clause is both exhaustive and inclusive. It is exhaustive to mean, any post or any place, while it includes any local area specified by the State Government. - Section 2(0)- This is an inclusive definition, which refers to a police officer at the station house, placed next in rank to the officer in charge, and is above the rank of constable, unless the State Government otherwise so directs. (Para 4)

Andhra Pradesh Reorganisation Act, 2014- Section 2(f) - The term ‘law’ includes an order or other instrument having the force of law, and therefore, brings within its ambit a notification or a circular issued by a competent authority - Section 100-102 - Section 100 is a transitional provision, making the application of the existing law to the two States, conscious enough not to create any legal vacuum - There is indeed no requirement for any specific order of adoption, particularly for the State of Andhra Pradesh - The State of Andhra Pradesh continues to be the same State, as what has been done is, by merely carving out some of its territories, a new State has been created.  (Para 8-10) The legal fiction should be so that the existing laws, prior to bifurcation, would continue to be in force in both the States, unless altered, repealed or amended in accordance with law. (Para 26)

Factual Context

The High Court of Andhra Pradesh quashed several FIRs registered between 2016 and 2020 by the ACB's Central Investigation Unit in Vijayawada- Grounds for Quashing: The respondents argued that the Vijayawada office was never formally notified as a "police station" under Section 2(s) of the CrPC after the 2014 state reorganization, rendering the FIRs void for lack of jurisdiction -Government Stance: The State argued that the original 2003 notification (G.O.Ms. No. 268) declaring ACB offices as police stations remained valid law under the Andhra Pradesh Reorganisation Act, 2014 -Setting Aside the Quashing: The Supreme Court set aside the High Court's judgment, calling the "hyper-technical approach" a "travesty of justice"- The Court ordered the investigation to proceed and directed that final reports be filed within six months-: The High Court was directed not to entertain any further challenges to the FIRs or the pending investigations on these jurisdictional grounds.

Case Info

Key details

  • Case name: Joint Director (Rayalaseema), Anti-Corruption Bureau, A.P. & Anr. etc. v. Dayam Peda Ranga Rao etc.
  • Neutral citation: 2026 INSC 37.
  • Coram: M.M. Sundresh, J.; Satish Chandra Sharma, J.
  • Judgment date: January 08, 2026.

Caselaws and citations

  • State of Punjab v. Balbir Singh, (1976) 3 SCC 242.
  • Commissioner of Commercial Taxes, Ranchi v. Swarn Rekha Cokes & Coals (P) Ltd., (2004) 6 SCC 689.
  • Ranjan Sinha v. Ajay Kumar Vishwakarma, (2017) 14 SCC 774.
  • State of Madhya Pradesh v. Lafarge Dealers Association, (2019) 7 SCC 584.
  • State, CBI v. A. Satish Kumar, AIR 2025 SC 913.

Statutes/laws referred

  • Code of Criminal Procedure, 1973: Sections 2(s) (police station), 2(o) (officer in charge).
  • Bharatiya Nagarik Suraksha Sanhita, 2023 (pari materia reference).
  • Prevention of Corruption Act, 1988.
  • Andhra Pradesh Reorganisation Act, 2014: Sections 2(f) (definition of law), 100 (territorial extent), 101 (adaptation of laws), 102 (construe laws).
  • Government Orders/Circulars:
    • G.O.Ms. No. 268, Home (PSC), 12.09.2003 (ACB offices as police stations; JD CIU ACB Hyderabad jurisdiction over entire undivided A.P.).
    • Circular Memo No. 13665/SR/2014, 26.05.2014 (continuity of laws post-bifurcation).
    • Circular Memo No. 25735/GPM&AR/2015, 01.12.2015 (admin shifting instructions).
    • Circular Memo No. 53023/6/GPM&AR/2016-9, 24.05.2016 (HoDs shifting).
    • DG ACB letter C.No.3/A3/2014-16, 17.10.2016 (shift to Vijayawada).
    • G.O.Ms. No. 137, Home (Services-III), 14.09.2022 (clarifying JD CIU ACB Vijayawada as police station with State-wide jurisdiction).