The Supreme Court has clarified that First Information Reports (FIRs) registered across multiple states cannot be clubbed together when they arise from separate transactions involving distinct complainants, evidence, and circumstances. The ruling came in the context of a multi-crore financial scam in which several FIRs had been lodged against the appellant in different jurisdictions.
A Bench comprising the Chief Justice of India and Justice K. Vinod Chandran examined whether it would be permissible to consolidate all these FIRs into a single proceeding. The Court held that such a step would not only be legally impermissible but also practically unworkable. It emphasized that clubbing FIRs is justified only when they relate to the same incident or series of events forming part of a single transaction.
In reaching its decision, the Court distinguished the present case from earlier precedents such as Amish Devgan v. Union of India. In that case, multiple FIRs had been registered across the country in response to allegedly derogatory remarks made during the telecast of a single television program. Since the alleged offense was one and the same across jurisdictions, the Court had allowed consolidation. However, the present matter was found to be different, as it involved multiple acts of alleged fraud, committed at different times and in different places, with separate sets of complainants and witnesses.
The Court pointed out that allowing such cross-state consolidation would create significant complications in trial. Different FIRs might involve varied penal provisions, separate evidentiary material, and distinct witnesses, making it impossible to conduct a joint trial without jeopardizing fairness and efficiency. The Court further noted that such an approach would overburden a single court with proceedings that are better adjudicated within their own jurisdictions.
While the Court refused to allow nationwide consolidation, it did provide limited relief by directing that FIRs registered within the same state could be transferred and tried together. In Telangana, for instance, multiple FIRs registered at different police stations, such as Cyberabad and Madhapur, were ordered to be transferred to the Economic Offences Wing to avoid duplication of effort. Similarly, in Maharashtra, an FIR registered at Thane was directed to be consolidated with another lodged at Ambazari, Nagpur. This approach, the Court observed, would reduce multiplicity of proceedings within a state while still preserving the jurisdictional integrity of separate states.
The Court rejected the plea to club FIRs registered in Karnataka, West Bengal, Delhi, Andhra Pradesh, and Rajasthan with those in other states. It reiterated that each of these FIRs must be investigated and tried independently, as they pertain to distinct incidents of alleged fraud affecting different victims.
By this ruling, the Supreme Court reaffirmed the principle that consolidation of FIRs is not a blanket remedy but a carefully limited tool available only in cases where the offenses stem from a single transaction. The judgment underscores the balance between efficiency in investigation and the need to respect the jurisdictional and factual boundaries of each case.
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