Secretary, Minor Irrigation & Rural ... vs Sahngoo Ram Arya And Anr. on 7 May, 2002
In the decision Secretary v. Sahngoo Ram Arya reported in (2002) 5 SCC 521, the Honourable Supreme Court has held that the High Court has power under Article 226 to direct an enquiry by CBI, and a decision to direct an enquiry by CBI against a person can only be done if the High Court after considering the material on record comes to a conclusion that such material does disclose a prima facie case calling for an investigation by CBI or any other similar agency.