In a significant ruling on corruption allegations in public recruitment, the Madras High Court has directed the State police to register a First Information Report (FIR) in connection with an alleged large-scale recruitment scam in the Municipal Administration and Water Supply (MAWS) Department.
A Division Bench led by Chief Justice Manindra Mohan Shrivastava and Justice G. Arul Murugan delivered the common order on February 20, 2026, holding that the material shared by the Enforcement Directorate (ED) prima facie disclosed cognizable offences that required immediate registration of a case.
Read also:- Bombay High Court Allows Single Mother to Change Daughter’s Name, Caste in School Record
Background of the Case
Two writ petitions were placed before the court. One was filed as a public interest litigation by K. Athinarayanan. The second was filed by Rajya Sabha MP I.S. Inbadurai seeking registration of an FIR based on his representation dated December 13, 2025.
The controversy stems from recruitment to 2,538 posts - including Assistant Engineers, Junior Engineers and Town Planning Officers - in the MAWS Department.
According to the petitioners, candidates allegedly paid between ₹25 lakh and ₹35 lakh per post to secure appointments. The alleged racket came to light during a search conducted by the Enforcement Directorate at the residence of K.N. Ravichandran, brother of a sitting Minister of the department, in connection with a separate bank fraud case.
During that search, the ED claimed to have seized digital records, communications, selection lists and other materials pointing to a systematic job-for-cash operation. On October 27, 2025, the ED shared 232 pages of documents with the Director General of Police under Section 66(2) of the Prevention of Money Laundering Act.
Read also:- Jharkhand HC Seeks Answers on 437 Custodial Deaths, Orders Home Secretary to Clarify Judicial
Despite this, no FIR was registered. Instead, the State referred the matter to the Vigilance and Anti-Corruption Department for a preliminary enquiry after obtaining sanction under Section 17A of the Prevention of Corruption Act.
Court on Maintainability
The Bench first addressed the maintainability of the petitions.
It dismissed the public interest litigation filed by Athinarayanan, noting that several criminal cases were pending against him.
“The petitioner’s own affidavit reveals pending criminal cases. His bona fides are under serious cloud,” the court observed, refusing to entertain the PIL at his instance.
However, the court proceeded to examine the petition filed by MP I.S. Inbadurai on merits, noting that the allegations were based on material shared by a statutory investigating agency and not merely on personal claims.
Read also:- Karnataka High Court Cuts Jail Term in ATM Cloning Case, Enhances Fine to ₹2 Lakh Each
Core Legal Question: Is FIR Mandatory?
At the heart of the case was a crucial legal issue - whether the police were bound to register an FIR immediately upon receiving the ED’s communication, or whether they could conduct a preliminary enquiry first.
The State argued that under the new criminal law framework - the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 - a preliminary enquiry was permissible. It also contended that since the original bank fraud case and related ED proceedings had been quashed earlier, the shared material might not hold legal weight.
The Bench rejected this line of argument.
“The quashing of the bank fraud case has nothing to do with the incriminating materials seized relating to recruitment,” the court noted.
Relying heavily on the Constitution Bench judgment in Lalita Kumari v. Government of U.P., the court reiterated that registration of an FIR is mandatory if the information discloses a cognizable offence.
“The police officer cannot avoid his duty of registering offence if cognizable offence is disclosed,” the Bench quoted from precedent.
The judges further referred to subsequent Supreme Court rulings clarifying that preliminary enquiry in corruption cases is not mandatory where credible material already discloses an offence.
Importantly, the court underlined that the purpose of preliminary enquiry is limited - it cannot be used to delay registration indefinitely.
“Preliminary enquiry cannot be used as a shield to delay action once information discloses commission of cognizable offence,” the Bench observed.
Read also:- Karnataka High Court Cuts Jail Term in ATM Cloning Case, Enhances Fine to ₹2 Lakh Each
Court’s Observations on ED Communication
The judges carefully examined the ED’s letter and accompanying documents.
They noted that the communication was not a vague complaint but contained detailed material evidence collected during a statutory search. The court found that the documents prima facie indicated illegal gratification and organised misconduct in recruitment.
Given the seriousness of the allegations - involving thousands of public posts and large sums of money - the court said the matter required formal investigation under criminal law.
Read also:- Supreme Court Upholds Life Term in 2009 Indore Murder Case, Cites Strong Circumstantial Evidence
The Decision
Allowing the criminal writ petition filed by MP I.S. Inbadurai, the Madras High Court directed the State police to register an FIR based on the information shared by the Enforcement Directorate and proceed with investigation in accordance with law.
The public interest litigation filed by K. Athinarayanan was dismissed.
The court concluded that when statutory material discloses cognizable offences, the law mandates registration of an FIR without undue delay.
Case Title: K. Athinarayanan v. State & I.S. Inbadurai v. State of Tamil Nadu
Case No.: W.P.(MD) No.34197 of 2025 & W.P.(Crl.) No.74 of 2026
Decision Date: 20 February 2026
