No Ground For Repeated Enquiries On Overlapping Allegations Without Fresh Material: Andhra Pradesh High Court Dismisses PIL Against MedTech Park Officials

"The procedure so adopted cannot be found fault with and when there is no incriminating material or proper evidence to substantiate the allegations, the Government decided to drop further enquiry, which we do not find fault with." High Court of Andhra Pradesh, in a significant ruling dated July 15, 2026, held that the State Government is justified in terminating enquiry proceedings against public officials when multiple prior investigations have found the allegations to be unsubstantiated and there is no fresh incriminating material on record.

A Division Bench comprising Chief Justice Lisa Gill and Justice Challa Gunaranjan observed that the government cannot be faulted for taking a holistic view of the record to drop a repetitive third enquiry into overlapping allegations.

The petitioner, Villuri Venkata Ramana Murthy, filed a Public Interest Litigation (PIL) challenging G.O.Rt.No.1645 dated October 4, 2021, which dropped enquiry proceedings against the founder directors of the Andhra Pradesh MedTech Zone (AMTZ). The enquiry had been initiated over allegations of large-scale financial and procedural irregularities in the establishment of the medical manufacturing park at Visakhapatnam. The petitioner argued that the government mechanically dropped the proceedings despite a vigilance report recommending action.

The primary question before the court was whether the State Government was justified in dropping the third enquiry against the respondents via the impugned G.O.Rt.No.1645. The court was also called upon to determine whether a third enquiry could be sustained on allegations that substantially overlapped with two prior investigations which had already cleared the officials.

Prior Enquiries Had Already Cleared The Officials

The court noted that the allegations of financial and procedural irregularities had already been subjected to two separate detailed enquiries in 2017 and 2018. These investigations, conducted by the Director General of the Anti-Corruption Bureau (ACB) and the Director General of Vigilance and Enforcement, concluded that the allegations were entirely unfounded. Consequently, the government had dropped those proceedings via G.O.Rt.No.187 and G.O.Rt.No.308.

Bar On Multiple Enquiries Without Fresh Material

The respondents argued that under the Andhra Pradesh Government Business Rules, there is a clear bar against conducting a third enquiry into the same set of allegations in the absence of any fresh material or new facts. The High Court analyzed the nature of the allegations across the multiple complaints and noted that they were significantly overlapping.

State Government Applied Its Mind To Detailed Explanations

The bench observed that the government did not act mechanically but carefully scrutinized the detailed explanation offered by the officials of the Andhra Pradesh MedTech Zone. The explanation highlighted that all key decisions were ratified by a board comprising Government of India officials, and estimates were vetted by technical committees from premier institutes like IIT, BARC, and ISOMED.

> "The 4th respondent, upon application of mind, has given exhaustive reasons on each of the allegations as to why it had to ultimately drop the ongoing inquiry."

Petitioner Failed To Provide Specific Evidence Of Misconduct

Addressing the petitioner's contentions, the court remarked that the petitioner failed to point out any specific instance of misconduct that the government had ignored. The court noted that the petitioner merely argued in a general manner that the inquiry was concluded summarily without examining necessary witnesses, without showing how the decision-making process was legally flawed.

Absence Of Incriminating Material Justifies Dropping Of Proceedings

The Court ultimately upheld the government's decision, emphasizing that in the absence of solid evidence, proceedings cannot be dragged on. It affirmed that the state had rightly evaluated the explanations in light of the previous clean chits and the global recognition of the MedTech Zone.

Consequently, the High Court found no merit in the Public Interest Litigation and dismissed the writ petition, closing all pending miscellaneous applications. The ruling reinforces that administrative authorities possess the discretion to terminate repetitive and unsubstantiated disciplinary enquiries to prevent unwarranted harassment of officials and organizations.

Date of Decision: July 15, 2026