Sanchayita Lahkar

The High Court of Andhra Pradesh Single Bench of Justice Harinath N held that the investigation into the allegations surrounding the preparation of Laddu Prasadam at Tirumala Tirupati must be conducted strictly by the Special Investigation Team (SIT) reconstituted as per the directions of the Hon'ble Supreme Court. The Court found that the actions of the 10th respondent, who was not a designated member of the SIT, in continuing investigation duties violated the Supreme Court’s directives. Consequently, the Court directed the Central Bureau of Investigation (CBI), represented by its Director, to supervise the ongoing investigation through the officially nominated SIT members alone. It further stated that the Director, CBI, could not have authorized the 10th respondent to function as Investigating Officer, as it would overreach the orders of the Supreme Court. The writ petition was allowed with clear instructions that the SIT constituted by the Supreme Court shall exclusively carry out the probe.

The petitioner, a former Special Officer at Andhra Pradesh Bhawan, filed a writ petition under Article 226 of the Constitution of India, seeking directions for a fair and impartial investigation by the SIT constituted pursuant to the Supreme Court's orders in WP(C) No. 622/2024 dated 04.10.2024. The petitioner also sought a declaration that the manner and conduct of the SIT officials was arbitrary, illegal, and without jurisdiction.

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The petitioner stated that he received a notice from the 10th respondent on 31.05.2025 requiring his appearance on 02.06.2025. Subsequently, a fresh notice dated 02.06.2025 directed him to appear on 03.06.2025. It was alleged that during this appearance, the petitioner was coerced into recording false statements dictated by the 10th respondent. These statements were allegedly recorded multiple times, with earlier versions deleted. The petitioner claimed the process was conducted in the presence of several police officers, including officials from the CBI and the State Police.

The background involves the registration of Crime No. 470 of 2024 regarding allegations of adulterated cow ghee being used in the preparation of sacred Laddu Prasadam at Tirumala. The issue gained significant attention after a public statement by the Chief Minister of Andhra Pradesh on 18.09.2024 suggesting the use of animal fat during the previous regime. Contradictory reports, including a statement from the Executive Officer of the Tirumala Tirupati Devasthanam (TTD), led to public outcry and the initiation of legal proceedings.

On 30.09.2024, the Supreme Court expressed concern over the potential impact of such public statements on devotees and requested the assistance of the Solicitor General to determine whether the existing SIT, constituted by the Andhra Pradesh government, should be retained or replaced. On 04.10.2024, the Supreme Court issued an order replacing the existing SIT with an independent SIT comprising two officers nominated by the Director of CBI, two by the Government of Andhra Pradesh, and one senior officer from the Food Safety and Standards Authority of India (FSSAI).

In compliance with the Supreme Court's directions, the CBI, by order dated 18.10.2024, named the following individuals as SIT members:

1. Shri S. Veeresh Prabhu, IPS, JD&HOZ, CBI, Hyderabad Zone

2. Shri Sarvashresth Tripathi, IPS, IGP, Andhra Pradesh Police

3. Shri Gopinath Jatti, IPS, DIG, Andhra Pradesh Police

4. Shri Murali Rambha, IPS, SP & HOB, CBI, ACB, Visakhapatnam

5. Satyen Kumar Panda, Advisor (Quality Assurance), FSSAI

The petitioner alleged that despite this specific composition, the 10th respondent, who was not included in the SIT, continued to summon and interrogate witnesses under the pretense of SIT authority. The 10th respondent also designated himself as the Investigating Officer under Section 179 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

The petitioner contended that such actions contravened the Supreme Court’s mandate and were beyond the legal authority of the 10th respondent. Furthermore, it was alleged that the 10th respondent’s prior involvement in the initial state-led SIT investigation created a conflict of interest.

The learned standing counsel for the CBI submitted that the Director, CBI, had authorized the 10th respondent to continue the investigation and that the SIT required assistance for procedural tasks such as serving notices. It was further argued that the Director’s decision was aimed at ensuring the continuity and efficiency of the investigation.

Reference was made to Supreme Court judgments including H.N. Rishbud vs. State of Delhi (1954), Bhanuprasad Hariprasad Dave vs. State of Gujarat (1968), and State of Bihar vs. Anil Kumar (2017), asserting that procedural lapses in investigation could be remedied at later stages.

However, the petitioner stated that the Supreme Court had specifically reconstituted the SIT with named individuals to maintain public confidence and ensure impartiality. Thus, any inclusion of individuals not formally appointed by the Supreme Court, such as the 10th respondent, undermined this objective.

Justice Harinath N observed that "the CBI could not have nominated the 10th respondent as the investigating agency contrary to the directions of the Hon’ble Supreme Court of India." The Court recorded that the Supreme Court had explicitly substituted the SIT constituted by the state with a new team consisting of designated officers.

It was stated, "The very purpose of entrusting the investigation by substituting the SIT constituted by the state ought to have been unambiguously interpreted by the Director, CBI and ought to have named any one of the officer of the reconstituted SIT as an investigating officer."

Addressing the claim that the Director, CBI, had merely sought logistical support, the Court recorded, "Inclusion of 10th respondent as investigating officer over and above the number of reconstituted SIT is not permissible and would certainly over reach the directions of the Hon’ble Supreme Court of India."

It was also noted that, "The submissions of the learned standing counsel that the Director, CBI is empowered to nominate the 10th respondent as investigating officer is unsustainable."

The Court acknowledged the arguments based on precedent but differentiated the current case, stating, "The judgments relied upon by the learned standing counsel cannot be made applicable to the peculiar facts and circumstances of the present case."

Importantly, the Court considered the broader implications, remarking, "The case on hand involves religious sentiments of the crores of devotees and the cloud on the invaluable sacredness of the Laddu Prasadam is being investigated."

Regarding the composition of the original SIT constituted by the state, the Court noted the overlap between some state officers and the newly constituted SIT. It stated, "The two SIT members i.e., Sri. Sarvashresth Tripathi, IPS, IGP Guntur Range and Sri Gopinath Jatti, IPS, DIG, Visakhapatnam Range, who were recommended by the State in the reconstituted SIT were already members of the SIT constituted by the State." Yet, it was clearly held that only those named in the Supreme Court’s final order were authorized.

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The Court reiterated the specific mandate of the Supreme Court: "The Hon’ble Supreme Court constituted an independent agency only to assuage the feelings of crores of people/devotees having faith in the deity."

Finally, the Court found that the 10th respondent had no lawful authority to act in the capacity of Investigating Officer in the reconstituted SIT and that any directions or actions taken by him in that capacity were ultra vires.

The Court issued the following directive: "The writ petition is allowed directing the respondent No.2 to conduct a free and fair investigation by supervising the investigation which is to be conducted by the SIT reconstituted as per the directions of the Hon’ble Supreme Court in WP. (C). No.622 of 2024."

The Court also stated that "the miscellaneous petitions pending, if any, shall stand closed."

Advocates Representing the Parties:

For the Petitioner: Uday Kumar Vampugadavala, Advocate

For the Respondents: GP for Home; P S P Suresh Kumar, Special Public Prosecutor for CBI

Case Title: Kaduru Chinnappanna v. State of Andhra Pradesh & Ors.

Neutral Citation: APHC010282122025

Case Number: WP.No.14239 of 2025

Bench: Justice Harinath N