The Supreme Court held that nationwide consolidation of FIRs with different witnesses, evidence, and laws is not permissible, allowing clubbing only for FIRs from the same incident, while rejecting a plea to merge multi-crore scam FIRs.
The Supreme Court ruled that the nationwide consolidation of FIRs involving different witnesses, evidence, and local laws is not permissible.
The Court clarified that such clubbing is only allowed when multiple FIRs arise from the same incident or transaction.
A bench comprising Chief Justice of India BR Gavai and Justice K. Vinod Chandran rejected the request to merge several FIRs filed in various states against the Appellant in a multi-crore financial scam.
The Justices emphasized that each FIR presented unique facts, witnesses, and legal frameworks, rendering nationwide consolidation impractical.
The Appellant cited the case of Amish Devgan v. Union of India (2021), where FIRs were consolidated due to being linked to a single televised statement.
However, Justice Chandran differentiated this case, stating,
“In Amish Devgan, the offence alleged was a single objectionable statement on a television broadcast, leading to multiple FIRs on the same cause of action. By contrast, in the present case, FIRs have been filed by different investors and depositors claiming they were cheated by diversion of funds. Each complaint involves separate victims and evidence. Once chargesheets are filed, trials would require producing investor-witnesses from different locations. In such circumstances, nationwide clubbing of FIRs is impractical.”
While it rejected pan-India consolidation, the Court allowed for the clubbing of FIRs within individual states. In Telangana, for example, four FIRs were registered three with the Economic Offences Wing (EOW), Cyberabad, and one at Madhapur, Cyberabad.
The Court directed that the FIR from Madhapur be transferred to the EOW. Similarly, in Maharashtra, two FIRs were identified one in Ambazari, Nagpur City, and another at Wagle Estate, Thane City. The Court ordered the transfer of FIR No. 210/2025 from Wagle Estate to Ambazari.
However, it declined to consolidate the FIRs filed in Karnataka, West Bengal, Delhi, Andhra Pradesh, and Rajasthan.
In conclusion, the Court determined that FIRs may only be clubbed within the same state, not across state lines.
Case Title: Odela Satyam & Anr. v. State of Telangana & Ors.
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