RAVINDER SINGH SIDHU versus THE STATE OF PUNJAB & ORS.
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[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 Courtβs power u/Arts.32 and 142 of the Constitution. Headnotesβ Constitution of India β Arts.32, 142 β Clubbing and consolidation of FIRs β Multiplicity of proceedings β Petition u/Art.32 for clubbing and transfer of FIRs in different States β Petitioner facing 64 FIRs in 10 States β Similar allegations arising out of a common scheme β Writ petition seeking clubbing FIRs within the respective States: Held: Multiplicity of proceedings not in public interest β 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 β Correct course of action would be to merge the FIRs with the earliest FIR in the State concerned β 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 β 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 β 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 β 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 *βAuthor [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 β Supplementary charge-sheets can be filed β Bail in principal FIR to apply to others unless distinct charges require fresh consideration β Only one FIR each in Chhattisgarh and Delhi, hence, not subject to clubbing β 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 β 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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