Institute of Legal and Management Studies

The Supreme Court on Friday (Sep.26) observed that nationwide consolidation of FIRs involving different witnesses, laws, and evidences is impermissible. It added that clubbing of FIRs is only permissible when multiple FIRs arise from the same incident/transactions.

A bench of Chief Justice of India BR Gavai and Justice K Vinod Chandran refused to club multiple FIRs registered against the Appellant across States in a multi crore financial scam, which involved different local laws, witnesses. The Court rejected the Appellants reliance on Amish Devgan v. Union of India (2021), which permitted consolidation of FIRs arising out of a single incident of hurting religious sentiments via telecasting in a television show, stating that the same was not permissible in the present case as the multiple FIRs registered were not part of the same incident.

Distinguishing Amish Devgan's case from the present case, the judgment authored by Justice Chandran observed:

“It has to be noticed that therein (Amish Devgan's case), the offence was one, of an alleged objectionable statement leading to hurting of religious sentiments telecast in a television show; which stands distinct from the instant case wherein FIRs were registered on the complaints of the investors of depositors who were alleged to have been duped by the firm diverting the funds leading to loss of their life's savings. We cannot forget that after investigation if a charge sheet is filed, the trial will have to be proceeded with, producing witnesses, being the investors of depositors, from the various locations. In which event the clubbing of FIRs from all the States would not be practical.”

However, the Court clubbed the FIRs registered in each State.

“As we noticed, in Telangana there were 4 crimes registered, three by the Economic Offences Wing, Cyberabad and one in Madhapur, Cyberabad. Hence the FIR registered in Madhapur, Cyberabad will stand transferred to Economic Offences Wing, Cyberabad. In the State of Maharashtra, there are two FIRs registered, One in Ambazari, Nagpur city and the other in Wagle Estate, Thane City. The FIR 210 of 2025 registered in Wagle Estate, Thane City will be transferred to Ambazari, Nagpur City. The clubbing of the single FIRs filed in the State of Karnataka, West Bengal, Delhi, Andhra Pradesh and Rajasthan stand rejected.”, the court said.

Resultantly, the petition was disposed of with the aforesaid direction clubbing FIRs in different part of the States to one FIR in each State.

Cause Title: Odela Satyam & Anr. Versus The State of Telangana & Ors.

Citation : 2025 LiveLaw (SC) 958

Click here to read/download the judgment

Appearance:

For Petitioner(s) : Ms. Rukmani Bobde, Adv. Mr. Mohd Faraz Anees, AOR Mr. Kartik Vashisht, Adv. Mr. Devesh Tripathi, Adv. Mr. Mukeshwar Nath Dubey, Adv. Mr. Ajay Kumar, Adv. Ms. Karuna Sharma, Adv. Ms. Epsita Agastya, Adv. Mr. Divesh, Adv. Mr. Anand, Adv. Mr. Shivendu Sharma, Adv. Mr. Kaustubh Seth, Adv. Mr. K. Parameshwar, Sr. Adv. Mr. Sarvam Ritam Khare, AOR Ms. Jayasree Narasimhan, Adv. Mr. Mohammad Ehtesham Aamir, Adv. Ms. Shweta Chaurasia, Adv. Mr. Kushagra Sharma, Adv. Mr. Akarsh Khare, Adv. Mr. Dama Seshadri Naidu, Sr. Adv. Mr. P. Mohith Rao, AOR Ms. J. Akshitha, Adv. Mr. Eugene S Philomene, Adv. Ms. D. Poornima, Adv.

For Respondent(s) : Mr. Kumar Vaibhaw, Adv. Ms. Devina Sehgal, AOR Mr. Srikanth Varma Mudunuru, Adv. Mr. Guntur Pramod Kumar, AOR Ms. Prerna Singh, Adv. Mr. Dhruv Yadav, Sr. Adv. Mr. Sanchit Garga, AOR Mr. Shashwat Jaiswal, Adv. Mr. Siddharth Dharmadhikari, Adv. Mr. Aaditya Aniruddha Pande, AOR Mr. Shrirang B. Varma, Adv. Mr. Bharat Bagla, Adv. Mr. Sourav Singh, Adv. Mr. Aditya Krishna, Adv. Mr. Adarsh Dubey, Adv. Ms. Chitransha Singh Sikarwar, Adv. Mr. S.D. Sanjay Ld, A.S.G. Mr. Mukesh Kumar Maroria, AOR Mr. Rajan Kumar Chourasia, Adv. Mr. Padmesh Mishra, Adv. Mr. Gaurang Bhushan, Adv. Ms. Mili Joy Baxi, Adv. Mr. Padmesh Mishra, A.A.G. Mr. S. Udaya Kumar Sagar, AOR Mr. Kshitij Mittal, Adv. Ms. Nidhi Jaswal, AOR Mr. Udaibir Singh Kochar, Adv. Mr. Utsav Garg, Adv. Mr. Ananta Prasad Mishra, AOR Mr. Kunal Mimani, AOR