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RAVINDER SINGH SIDHU versus THE STATE OF PUNJAB & ORS.

Citation: [2025] 5 S.C.R. 2648 · Decided: 19-05-2025 · Supreme Court of India · Bench: BHUSHAN RAMKRISHNA GAVAI · Disposal: Appeal(s) allowed

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Judgment (excerpt)

[2025] 5 S.C.R. 2648 : 2025 INSC 727
Ravinder Singh Sidhu 
v. 
The State of Punjab & Ors. 
(Writ Petition (Criminal) No. 394 of 2024)
19 May 2025
[B.R. Gavai, CJI and K.V. Viswanathan,* J.]
Issue for Consideration
Whether multiple FIRs registered across different States can be 
clubbed and consolidated in one jurisdiction, or at least within one 
district per State, under the Court’s power u/Arts.32 and 142 of 
the Constitution.
Headnotes†
Constitution of India – Arts.32, 142 – Clubbing and consolidation 
of FIRs – Multiplicity of proceedings – Petition u/Art.32 for 
clubbing and transfer of FIRs in different States – Petitioner 
facing 64 FIRs in 10 States – Similar allegations arising out 
of a common scheme – Writ petition seeking clubbing FIRs 
within the respective States:
Held: Multiplicity of proceedings not in public interest – Since many 
States have invoked local Acts, particularly the Act dealing with 
the Protection of Interest of Depositors, transferring them out of 
the State also will not serve the ends of justice – Correct course 
of action would be to merge the FIRs with the earliest FIR in the 
State concerned – If the first FIR in the respective States registered 
in respect of offence under the general law and not the special 
enactment, but if the subsequent FIRs now clubbed are registered 
in connection with the special law or registered also in connection 
with the special law, the same after clubbing must be tried under 
the special law by the Special Courts – While the first FIR will be 
treated as the First Information Report the subsequent FIRs in each 
State shall be treated as statements u/s.161 CrPC – Investigating 
Officer in the criminal case arising out of the principal FIR in the 
concerned State will be free to file supplementary chargesheets after 
the collation of all records concerning other FIRs in the concerned 
State which are clubbed in terms of this order – If Police Report 
u/s.173 CrPC stands already filed in the clubbed FIRs and the 
concerned Courts have taken cognizance thereof, said FIRs and 
* Author
[2025] 5 S.C.R. 
2649
Ravinder Singh Sidhu v. The State of Punjab & Ors.
criminal cases would also stand transferred and merged/clubbed 
along with the principal FIR to be proceeded with in accordance 
with law – Supplementary charge-sheets can be filed – Bail in 
principal FIR to apply to others unless distinct charges require 
fresh consideration – Only one FIR each in Chhattisgarh and 
Delhi, hence, not subject to clubbing – Order in exercise of powers  
u/Art.32 read with Art.142 passed. [Paras 10, 19-22]
Case Law Cited
Radhey Shyam v. State of Haryana, 2022 SCC OnLine SC 1935; 
Abhishek Singh Chauhan v. Union of India, 2022 SCC OnLine 
SC 1936 – relied on. 
List of Acts
Penal Code, 1860; Code of Criminal Procedure, 1973; Prize Chits 
and Money Circulation Schemes (Banning) Act, 1978; Gujarat 
Police Act, 1951; Haryana Protection of Interest of Depositors in 
Financial Establishment Act, 2013; Madhya Pradesh Nikshepakon 
Ke Hiton Ka Sanrakshan Adhiniyam, 2000; Uttarakhand Protection 
of Interests of Depositors (in Financial Establishments) Act, 2005.
List of Keywords
Clubbed FIRs; Multiplicity of proceedings; Jurisdictional 
consolidation; Public interest; Criminal trial; Bail; Merging of FIRs; 
Principal FIR; General law; Special law; Multiple FIRs.
Case Arising From
CRIMINAL ORIGINAL JURISDICTION: Writ Petition (Criminal) 
No. 394 of 2024
Under Article 32 of The Constitution of India
Appearances for Parties
Advs. for the Petitioner:
Shyam Mehta, Sr. Adv., Mohit Paul, Ms. Rangoli Seth, Varad 
Kilor, Rohit.
Advs. for the Respondents:
Amit Sharma, Ms. Manisha Aggarwal, A.A.Gs., Siddhant Sharma, 
Yashraj Singh Bundela, Ms. Saloni, Arpit Garg, Dhruv Sharma, 
Akshay Amritanshu, Ms. Drishti Rawal, Ms. Pragya Upadhyay, Ms. 
2650
[2025] 5 S.C.R.
Supreme Court Reports
Drishti Saraf, Ms. Swati Ghildiyal, Ms. Abhipsa Mohanty, Mukesh 
Kumar Maroria, Bhuvan Kapoor, Anuj Udupa, Sharath Nambiar, 
Ms. Alabhaya Dhamija, Sudarshan Singh Rawat, Ms. Saakshi 
Singh Rawat, Ajay Kumar Bahuguna, Saurabh Rajpal, Vinay Kumar 
Singh, Arpit Bamal, Ashzad Mubarak, Ms. Nidhi Jaswal, Pradeep 
Misra, Daleep Dhyani, Suraj Singh.
Judgment / Order of the Supreme Court
Judgment
K.V. Viswanathan, J.
1.	
The present Writ Petition has been filed seeking to issue an 
appropriate writ, order or direction for clubbing and transferring 
the multiple First Information Reports (FIRs) registered against the 
p

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