If an inspector appointed under section 210 or section 212 or section 213 to investigate into the affairs of a company considers it necessary for the purposes of the investigation, to investigate also the affairs of—
a. any other body corporate which is, or has at any relevant time been the company's subsidiary company or holding company, or a subsidiary company of its holding company;
b. any other body corporate which is, or has at any relevant time been managed by any person as managing director or as manager, who is, or was, at the relevant time, the managing director or the manager of the company;
c. any other body corporate whose Board of Directors comprises nominees of the company or is accustomed to act in accordance with the directions or instructions of the company or any of its directors; or
d. any person who is or has at any relevant time been the company's managing director or manager or employee, he shall, subject to the prior approval of the Central Government, investigate into and report on the affairs of the other body corporate or of the managing director or manager, in so far as he considers that the results of his investigation are relevant to the investigation of the affairs of the company for which he is appointed.
Legal Commentary & Landmark Judgments: Section 219
Section 219 of the Companies Act, 2013 empowers an inspector, with prior approval of the Central Government, to expand an investigation into the affairs of related companies, subsidiaries, holding companies, and managing entities, codifying the statutory piercing of corporate veils across corporate groups.
When representing a related entity or group subsidiary served with an investigative summons under Section 219, file a preliminary objection demanding proof of prior Central Government approval. If the Central Government granted approval without recording the statutory nexus (e.g., holding-subsidiary relationship or common management control), challenge the authorization before the High Court under Article 226 as an ultra vires overreach beyond the original mandate.