IN THE HIGH COURT OF PUNJAB & HARYANA AT Pappu Sharma State of Haryana [ CORAM: Argued by SURYA PARTAP SINGH Suraksha Sanhita clubbing/consolidating the instance of police stations 2. a society named ‘Human Welfare Credit & Thrift Co Limited’, and that the abovementioned Society schemes, such as Fixed Deposits, Recurring Deposits, monthly income plan and ‘Sukanya Samridhi Yojana’ launched offered by Governmen invested amounts CRM-M-5177-2026 (O&M) IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH Pappu Sharma VERSUS Haryana & Ors. CORAM: HON’BLE MR. JUSTICE SURYA PARTAP SINGH Argued by: Mr. Nitin Bhanwala, Advocate Mr. Ramender Singh Chauhan ***** SURYA PARTAP SINGH, J. This petition under Section 528 of Suraksha Sanhita, 2023’, has been filed by the petitioner for clubbing/consolidating 10 FIRs, mentioned in Annexure P/1, the instance of different complainants on similar allegations police stations against the petitioner. In nut-shell the facts emerging from record a society named ‘Human Welfare Credit & Thrift Co , and that the abovementioned Society schemes, such as Fixed Deposits, Recurring Deposits, monthly income plan and ‘Sukanya Samridhi Yojana’. The with a claim of providing higher interest rates offered by Government Banks. The assurance of invested amounts was also given. Relying upon the abovesaid 1 IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH CRM-M-5177-2026 (O&M) Reserved on : 11.03.2026 Pronounced on : 21.04.2026 ..... Petitioner VERSUS ..... Respondent SURYA PARTAP SINGH , Advocate for the petitioner. Singh Chauhan, AAG Haryana. ***** under Section 528 of ‘the Bharatiya Nagarik , has been filed by the petitioner for , mentioned in Annexure P/1, registered complainants on similar allegations in different facts emerging from record are that there exists a society named ‘Human Welfare Credit & Thrift Co-operative Societ , and that the abovementioned Society offered various investment schemes, such as Fixed Deposits, Recurring Deposits, monthly income plan e abovementioned schemes w higher interest rates, than the ra . The assurance of complete safety of the . Relying upon the abovesaid (O&M) .2026 .2026 Petitioner ..... Respondents Bharatiya Nagarik , has been filed by the petitioner for registered at in different there exists operative Society offered various investment schemes, such as Fixed Deposits, Recurring Deposits, monthly income plans were ates complete safety of the . Relying upon the abovesaid GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document representations, the complainants in all the FIRs registered against the petitioner invested different sums of money in the abovementioned Societ However, after the year 2024, the Society stopped returning the invested amounts. It investors and 3. he had played petitioner against him, which pertain allegations. The petitioner has further a FIRs registered against him which read as under: Sr. No. FIR No. (i) 40 (ii) 49 (iii) 114 (iv) 134 CRM-M-5177-2026 (O&M) representations, the complainants in all the FIRs registered against the petitioner invested different sums of money in the abovementioned Societ However, after the year 2024, the Society stopped returning the invested . It has been alleged in the FIRs investors and usurped the money of investors/depositors The petitioner has further cla played an active or role in the commission of r, in a very clandestine manner, different FIRs have been lodged against him, which pertain to the same transactions allegations. The petitioner has further alleged that as on today there are ten FIRs registered against him. The details which read as under:- FIR No. Dated Sections 40 27.02.2025 120-B, 406, 408, 420 of IPC and Section 3 of the Haryana Protection of Interest of Depositors in Financial Establishment Act, 2013 and Sections 21 and 23 of Banning of Unregulated Deposit Schemes Act, 2019. 49 27.02.2025 120-B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 2013 and Sections 2 Act 114 27.02.2025 120-B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of BUDS Act 134 24.02.2025 120-B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 201 and Sections 21 and 23 of BUDS Act 2 representations, the complainants in all the FIRs registered against the petitioner invested different sums of money in the abovementioned Societ However, after the year 2024, the Society stopped returning the invested in the FIRs that the Society has cheated the of investors/depositors. aimed that there is no allegation t role in the commission of alleged offences. As in a very clandestine manner, different FIRs have been lodged to the same transactions and have similar lleged that as on today there are ten details of such FIRs have been provided, Sections Police Station B, 406, 408, 420 of IPC and Section 3 of the Haryana rotection of Interest of Depositors in Financial Establishment Act, 2013 and Sections 21 and 23 of Banning of Unregulated Deposit Schemes Sanoli, Panipat B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of BUDS Israna, Panipat B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of BUDS Industrial Sector-29, Panipat B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of BUDS Chandnibag h, Panipat representations, the complainants in all the FIRs registered against the petitioner invested different sums of money in the abovementioned Society. However, after the year 2024, the Society stopped returning the invested cheated the that per in a very clandestine manner, different FIRs have been lodged and have similar lleged that as on today there are ten have been provided, Police Station Sanoli, Panipat Israna, Panipat Industrial 29, Panipat Chandnibag h, Panipat GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document (v) 449 (vi) 22 (vii) 703 (viii) 392 (ix) 315 (x) 129 4. prosecutions, through different allegations by different complainants, which are of transactions and facts, and that the multiplicity serious prejudice to the petitioner’s right but also amount to abuse of process of law. clubbing of FIRs. 5. 6. the petitioner, who is a 50 working in a textile company at Panipat, is being prosecutions, arising out of the same transactions. According to learned counsel for the petitioner, Thrift Co CRM-M-5177-2026 (O&M) 449 12.11.2024 Section 420 IPC and Section 25 of BUDS Act 22 22.01.2025 Sections 316(2), 318(2) and 318(4) of BNS 703 17.12.2024 Sections 316(2), 31 BNS, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of BUDS Act 392 11.12.2024 Section 406 and 420 of IPC 315 18.08.2025 Section 120-B, 406 and 420 of IP and Section 3 of BUDS Act 129 27.02.2025 120-B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of BUDS Act According to the petitioner, prosecutions, through different FIRs registered allegations by different complainants, which are of transactions and facts, and that the multiplicity prejudice to the petitioner’s right but also amount to abuse of process of law. clubbing of FIRs. Heard. It has been contended by learned counsel for the petitioner that the petitioner, who is a 50-year-old respectable ng in a textile company at Panipat, is being prosecutions, arising out of the same transactions. According to learned counsel for the petitioner, a Society, namely ‘Human Welfare Credit & Thrift Co-operative Society Limited’, was offe 3 Section 420 IPC and Section 25 Tehsil Camp, Panipat Sections 316(2), 318(2) and 318(4) of BNS Murthal, Sonipat 316(2), 318(4), 61(2) of BNS, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of Thanesar, Kurukshetra Section 406 and 420 of IPC Munak, Karnal B, 406 and 420 of IP and Section 3 of BUDS Act Madhuban, Karnal B, 406, 408, 420 of IPC, Section 3 of HPIDFE Act, 2013 and Sections 21 and 23 of BUDS Samalkha, Panipat According to the petitioner, he has been subjected to multiple registered on similar and identical allegations by different complainants, which are arising out of the same set of transactions and facts, and that the multiplicity of the FIR not only causes prejudice to the petitioner’s right to fair investigation and defence, but also amount to abuse of process of law. Hence the present petition It has been contended by learned counsel for the petitioner that old respectable member of the Society ng in a textile company at Panipat, is being subjected to multiple prosecutions, arising out of the same transactions. According to learned a Society, namely ‘Human Welfare Credit & , was offering various investment Tehsil Camp, Panipat Murthal, Sonipat Thanesar, Kurukshetra Munak, Karnal Madhuban, arnal Samalkha, Panipat to multiple on similar and identical arising out of the same set of the FIR not only causes nce, Hence the present petition for It has been contended by learned counsel for the petitioner that member of the Society, subjected to multiple prosecutions, arising out of the same transactions. According to learned a Society, namely ‘Human Welfare Credit & ring various investment GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document schemes, assuring the complainant had invested in schemes. Society stopped investors levelled allegations of cheating against the Society, result multiple FIRs. 7. in the above accused, and that in any of the abovementioned FIRs, no specific role or active involvement has been attributed to the petitioner. As per learned counsel for the petitioner name of the petitioner course of investigation, merely with an intent petitioner, the Investigating Agency is now attempting According already filed charge and that in a most surprising the petitioner on the same very day Police Stations in the same District, which is Investigating Agency that the a of the prosecuti vague and uns 8. that the abovementioned pattern of registration of FIRs CRM-M-5177-2026 (O&M) schemes, assuring higher interest rates, and that various persons including the complainant had invested in those schemes, and reap s. As per learned counsel for the petitioner, Society stopped paying the benefit of invested money investors levelled allegations of cheating against the Society, result multiple FIRs. The learned counsel for the petitioner has further contended that in the abovementioned FIRs, the petitioner is being prosecuted as an accused, and that in any of the abovementioned FIRs, no specific role or active involvement has been attributed to the petitioner. As per learned counsel for the petitioner, in several of the aboveme name of the petitioner does not find mention course of investigation, merely with an intent petitioner, the Investigating Agency is now attempting According to learned counsel for the petitioner, already filed charge-sheets in two Districts, i.e. Kurukshetra and Sonipat in a most surprising manner, five FIRs have been registered against the petitioner on the same very day, i.e. on Police Stations in the same District, which is Investigating Agency. The learned couns abovementioned events give rise prosecuting agency, as the multiple vague and unsubstantiated allegations. It has also been contended by learned counsel for the petitioner the abovementioned pattern of registration of FIRs 4 higher interest rates, and that various persons including schemes, and reaped the benefit of the As per learned counsel for the petitioner, in the year 2024, invested money, and therefore, the investors levelled allegations of cheating against the Society, resulting into The learned counsel for the petitioner has further contended that mentioned FIRs, the petitioner is being prosecuted as an accused, and that in any of the abovementioned FIRs, no specific role or active involvement has been attributed to the petitioner. As per learned in several of the abovementioned FIRs, even the does not find mention at initial stage, but, during the course of investigation, merely with an intent to falsely implicate the petitioner, the Investigating Agency is now attempting to add his name to learned counsel for the petitioner, the Investigating Agency has in two Districts, i.e. Kurukshetra and Sonipat manner, five FIRs have been registered against , i.e. on 27.02.2025, in five different Police Stations in the same District, which is very unusual on the part of the sel for the petitioner has contend e to serious doubt on the intentions multiple FIRs have been lodged, containing It has also been contended by learned counsel for the petitioner the abovementioned pattern of registration of FIRs is arbitrary and casts higher interest rates, and that various persons including the benefit of the 24, the and therefore, the into The learned counsel for the petitioner has further contended that mentioned FIRs, the petitioner is being prosecuted as an accused, and that in any of the abovementioned FIRs, no specific role or active involvement has been attributed to the petitioner. As per learned ntioned FIRs, even the , during the to falsely implicate the to add his name. the Investigating Agency has in two Districts, i.e. Kurukshetra and Sonipat, manner, five FIRs have been registered against 27.02.2025, in five different on the part of the ded intentions containing It has also been contended by learned counsel for the petitioner is arbitrary and casts GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document a shadow process. As per lear have been filed against the petitioner, similar have been levelled, and that the pattern of abovementioned cases clearly indicates a targeted and mechanical While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘The State (NCT) of Delhi V/s Khimji Bhai Jadeja’ Neutral Citation 2026 INSC 25 has contended that instant case is squarely covered by the principles of law propounded direction to the learned trial Court to club/consolidate all the ten FIRs view of the settled position of law Court of India in the case of ‘Alok Kumar Vs State of Bihar & Ors.’ SLP(Crl) No.4073/2025. 9. abovementioned arguments. According to learned State Counsel, in the present case, th Districts, at the instance of different complainants in cause of action for each of the by learned State Counsel that the f stations of different Districts FIRs have been filed with Counsel, having any design to harass the petitioner. CRM-M-5177-2026 (O&M) a shadow of suspicion over the fairness a As per learned counsel for the petitioner, all the ten cases, which have been filed against the petitioner, similar have been levelled, and that the pattern of abovementioned cases clearly indicates a targeted and mechanical approach by While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘The State (NCT) of Delhi V/s Khimji Bhai Neutral Citation 2026 INSC 25, the learned ontended that instant case is squarely covered by the principles of law propounded in the abovementioned case, and therefore, there should be a direction to the learned trial Court to club/consolidate all the ten FIRs view of the settled position of law prop Court of India in the case of ‘Alok Kumar Vs State of Bihar & Ors.’ SLP(Crl) No.4073/2025. The learned State Counsel has controverted the abovementioned arguments. According to learned State Counsel, in the present case, the filing of ten FIRs, in different , at the instance of different complainants in cause of action for each of the FIRs was different by learned State Counsel that the filing of different FIRs in different police of different Districts, demolishes FIRs have been filed with mala fide there is no force in the allegatio having any design to harass the petitioner. 5 and impartiality of the investigative ned counsel for the petitioner, all the ten cases, which have been filed against the petitioner, similar false and baseless allegations have been levelled, and that the pattern of abovementioned cases clearly approach by the Investigating Agency. While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘The State (NCT) of Delhi V/s Khimji Bhai , the learned counsel for the petitioner ontended that instant case is squarely covered by the principles of law in the abovementioned case, and therefore, there should be a direction to the learned trial Court to club/consolidate all the ten FIRs, pounded by the Hon’ble Supreme Court of India in the case of ‘Alok Kumar Vs State of Bihar & Ors.’ The learned State Counsel has controverted the abovementioned arguments. According to learned State Counsel, in the in different police stations in different , at the instance of different complainants in itself shows that was different. It has also been contended iling of different FIRs in different police demolishes the plea of the petitioner that the intentions. As per learned St on that the Investigating Agency is having any design to harass the petitioner. of the investigative ned counsel for the petitioner, all the ten cases, which false and baseless allegations have been levelled, and that the pattern of abovementioned cases clearly the Investigating Agency. While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘The State (NCT) of Delhi V/s Khimji Bhai counsel for the petitioner ontended that instant case is squarely covered by the principles of law in the abovementioned case, and therefore, there should be a , in by the Hon’ble Supreme Court of India in the case of ‘Alok Kumar Vs State of Bihar & Ors.’ The learned State Counsel has controverted the abovementioned arguments. According to learned State Counsel, in the police stations in different that the It has also been contended iling of different FIRs in different police the plea of the petitioner that the tate the Investigating Agency is GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document 10. has approached different police stations action, and therefore, different FIRs have been stations. As per learned State Counsel, since the Invest abovementioned cases are different, the allegations of on the part of the Investigating Agency cannot sustain. The learned State Counsel while referring to the principles of law laid down in the case of ‘State of 1963 SC 1850 cause of action transactions 11. the course of investigation, specific role of the petitioner has been found in the commission of offence, and that the charge already been possible. While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘Khimji Bhai Jadeja’ (supra), the learned State Counsel has contended that th petitioner is trial. 12. 13. here that the petit charge-sheet CRM-M-5177-2026 (O&M) According to learned State Counsel, each of the complainant has approached different police stations action, and therefore, different FIRs have been As per learned State Counsel, since the Invest abovementioned cases are different, the allegations of on the part of the Investigating Agency cannot sustain. The learned State Counsel while referring to the principles of law laid down in the case of State of Andhra Pradesh V/s Cheemalapati SC 1850, has contended that each of the complainant has a separate cause of action, as every such complainant transactions at different point of time, and It has also been contended by learned State Counsel that the course of investigation, specific role of the petitioner has been found in the commission of offence, and that the charge already been filed, and thus, at this stage, the consolidation of possible. While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘Khimji Bhai Jadeja’ (supra), the learned State Counsel has contended that th petitioner is to approach the learned trial Court and seek the consolidation The record has been perused carefully. In the present case, at the very outset it is pertinent to mention here that the petitioner, in para No.4 of the petition sheets in two cases in District Kurukshetra 6 learned State Counsel, each of the complainant has approached different police stations, according to his own cause of action, and therefore, different FIRs have been lodged in different police As per learned State Counsel, since the Investigating Agency in the abovementioned cases are different, the allegations of mala fide intentions on the part of the Investigating Agency cannot sustain. The learned State Counsel while referring to the principles of law laid down in the case of Andhra Pradesh V/s Cheemalapati Ganeswara Rao &Anr.’ AIR , has contended that each of the complainant has a separate every such complainant had a different kind of and different amounts were deposited It has also been contended by learned State Counsel that during the course of investigation, specific role of the petitioner has been found in the commission of offence, and that the charge-sheet in several cases have filed, and thus, at this stage, the consolidation of FIRs is not possible. While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘Khimji Bhai Jadeja’ (supra), the learned State Counsel has contended that the proper course available to the to approach the learned trial Court and seek the consolidation The record has been perused carefully. In the present case, at the very outset it is pertinent to mention of the petition, has contended that in two cases in District Kurukshetra and Sonipat have already learned State Counsel, each of the complainant cause of lodged in different police igating Agency in the intentions on the part of the Investigating Agency cannot sustain. The learned State Counsel while referring to the principles of law laid down in the case of Ganeswara Rao &Anr.’ AIR , has contended that each of the complainant has a separate had a different kind of ed. during the course of investigation, specific role of the petitioner has been found in sheet in several cases have FIRs is not possible. While referring to the principles of law laid down by the Hon’ble Supreme Court of India in the case of ‘Khimji Bhai Jadeja’ (supra), the e proper course available to the to approach the learned trial Court and seek the consolidation of In the present case, at the very outset it is pertinent to mention has contended that and Sonipat have already GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document been filed. complaints have been filed by several respective Thrift Co- it has been found that attributable to the pe 14. Bhai Jadeja’ (supra), case, a finding recorded by the Division Bench of Delhi High on the following question has been set aside. The question framed by the Division Bench of Delhi High Court was: 15. Bench in the following CRM-M-5177-2026 (O&M) been filed. In the present case, this fact cannot be ignored that several complaints have been filed by several respective transactions with the society, namely ‘Human Welfare Credit & -operative Society Limited’, and during the course of investigation, it has been found that specific role, in the commission of offence attributable to the petitioner. The Hon’ble Supreme Court of India in the case of ‘Khimji Bhai Jadeja’ (supra), has dealt with the a finding recorded by the Division Bench of Delhi High on the ing question has been set aside. The question framed by the Division Bench of Delhi High Court was:- ‘a. Whether in a case of inducement, allurement and cheating of large number of investors/depositors in pursuance to a criminal conspiracy, each deposit by separate and individual transaction or all such transactions can be amalgamated and clubbed into a single FIR by showing one investor as complainant and other as witnesses? The abovementioned question Bench in the following words:- ‘…. Thus, our answer to Question (a) is that in a case of inducement, allurement and cheating of large number of investors/depositors in pursuance to a criminal conspiracy, each deposit by an investor constitutes a sep individual transaction. All such amalgamated and clubbed into a single FIR by showing one investor as the complainant and others as witnesses. In respect of each such transaction, it is imperative for the State to 7 this fact cannot be ignored that several complaints have been filed by several complainants with regard to their with the society, namely ‘Human Welfare Credit & and during the course of investigation, in the commission of offence, Hon’ble Supreme Court of India in the case of ‘Khimji similar situation. In the abovesaid a finding recorded by the Division Bench of Delhi High on the ing question has been set aside. The question framed by the Division Whether in a case of inducement, allurement and cheating of large number of investors/depositors in pursuance to a , each deposit by an investor constitutes a separate and individual transaction or all such transactions can be amalgamated and clubbed into a single FIR by showing one investor as complainant and other as witnesses?’ The abovementioned question was answered by the Division …. Thus, our answer to Question (a) is that in a case of inducement, allurement and cheating of large number of investors/depositors in pursuance to a criminal conspiracy, each deposit by an investor constitutes a separate and individual transaction. All such transactions cannot be amalgamated and clubbed into a single FIR by showing one investor as the complainant and others as witnesses. In respect of each such transaction, it is imperative for the State to this fact cannot be ignored that several th regard to their with the society, namely ‘Human Welfare Credit & and during the course of investigation, , is Hon’ble Supreme Court of India in the case of ‘Khimji situation. In the abovesaid a finding recorded by the Division Bench of Delhi High on the ing question has been set aside. The question framed by the Division Whether in a case of inducement, allurement and cheating of large number of investors/depositors in pursuance to a an investor constitutes a separate and individual transaction or all such transactions can be amalgamated and clubbed into a single FIR by showing vision …. Thus, our answer to Question (a) is that in a case of inducement, allurement and cheating of large number of investors/depositors in pursuance to a criminal conspiracy, arate and cannot be amalgamated and clubbed into a single FIR by showing one investor as the complainant and others as witnesses. In respect of each such transaction, it is imperative for the State to GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document 16. High could not hold However, it has been observed ‘Section 218(1) CrPC requires a distinct and separate charge for every distinct offence and each 219 to 223 CrPC constitute exceptions to this general rule and stipul circumstances in which devia CrPC, three such offences committed during a year can be the subject matter of a single trial [now, five such offences, under Section 242 of the Bharatiya Nagarik Suraksha Sa 223(a) and (d) CrPC, consolidated charges can be framed against several accused persons in relation to several offences, if such offences are committed during the course of the same transaction. It would, turn upon the offences forming part of the 17. ‘precedential law has laid down triple tests, though not to be applied cumulatively, to decide when separate actio 'same transaction' CRM-M-5177-2026 (O&M) register a separate FIR if the complainant discloses commission of a cognizable offence. The abovementioned observations of could not hold good before the Hon’ble Supreme Court of India. However, it has been observed by the Hon’ Section 218(1) CrPC requires a distinct and separate charge for every distinct offence and each separate charge should be tried separately. Sections 219 to 223 CrPC constitute exceptions to this general rule and stipul circumstances in which deviațion therefrom can be made. Under Section 219 CrPC, three such offences committed during a year can be the subject matter of a single trial [now, five such offences, under Section 242 of the Bharatiya Nagarik Suraksha Sanita, 2023 (BNSS)]. Under Sections 220(1) CrPC and 223(a) and (d) CrPC, consolidated charges can be framed against several accused persons in relation to several offences, if such offences are committed during the course of the same transaction. It would, turn upon the offences forming part of the The Hon’ble Supreme Court of India has further observed that precedential law has laid down triple tests, though not to be applied cumulatively, to decide when separate actio 'same transaction'. The abovesaid parameters (i) unity of purpose and design; (ii) proximity of time and place; and (iii) continuity of action. 8 a separate FIR if the complainant discloses commission of a cognizable offence.’ observations of Division Bench of Delhi the Hon’ble Supreme Court of India. by the Hon’ble Supreme Court of India that Section 218(1) CrPC requires a distinct and separate charge for every separate charge should be tried separately. Sections 219 to 223 CrPC constitute exceptions to this general rule and stipulate the țion therefrom can be made. Under Section 219 CrPC, three such offences committed during a year can be the subject matter of a single trial [now, five such offences, under Section 242 of the Bharatiya nita, 2023 (BNSS)]. Under Sections 220(1) CrPC and 223(a) and (d) CrPC, consolidated charges can be framed against several accused persons in relation to several offences, if such offences are committed during the course of the same transaction. It would, therefore, turn upon the offences forming part of the ‘same transaction’.’ The Hon’ble Supreme Court of India has further observed that precedential law has laid down triple tests, though not to be applied cumulatively, to decide when separate actions can be treated as part of the parameters are :- ) unity of purpose and design; ) proximity of time and place; and a separate FIR if the complainant discloses Division Bench of Delhi the Hon’ble Supreme Court of India. that Section 218(1) CrPC requires a distinct and separate charge for every separate charge should be tried separately. Sections ate the țion therefrom can be made. Under Section 219 CrPC, three such offences committed during a year can be the subject matter of a single trial [now, five such offences, under Section 242 of the Bharatiya nita, 2023 (BNSS)]. Under Sections 220(1) CrPC and 223(a) and (d) CrPC, consolidated charges can be framed against several accused persons in relation to several offences, if such offences are therefore, The Hon’ble Supreme Court of India has further observed that precedential law has laid down triple tests, though not to be applied ns can be treated as part of the GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document 18. tests may be applied to ascertain whether a series of acts form part of the same transaction or not. It is not necessary at the present stage to consider whether consolidation of charges under Section 220(1) CrPC should be resorted to, as that would depend upon the opinion of the Magistrate on the strength of the findings recorde all the incidents partake of the same transaction, there can be one trial under Section 220(1) CrPC and Section 223(a) and concluded that there are several transactions and disti to different victims, there have to be separate trials for each offence, subject to Section 219 CrPC/ Section 242 BNSS, which allows the Trial Court to try three/five offences of the same kind committed within a year 19. case has also observed that that would depend As per Hon’ble Supreme Court of India, in the above procedure was adopted by the Delhi Police in registering one FIR and treating the complaint under Section 161 CrPC inference to be Judicial Magistrate concerned to consider, so as to various acts of cheating attributed to the accused persons constitute part of the same transaction 220(1) CrPC and Section 223(a) & (d) CrPC Supreme Court of India, if the offence formed CRM-M-5177-2026 (O&M) As per Hon’ble Supreme Co tests may be applied to ascertain whether a series of acts form part of the same transaction or not. It is not necessary at the present stage to consider whether consolidation of charges under Section 220(1) CrPC should be resorted to, as that would depend upon the opinion of the Magistrate on the strength of the findings recorded during the investigation. If it is opined that all the incidents partake of the same transaction, there can be one trial under Section 220(1) CrPC and Section 223(a) and concluded that there are several transactions and disti to different victims, there have to be separate trials for each offence, subject to Section 219 CrPC/ Section 242 BNSS, which allows the Trial Court to try three/five offences of the same kind committed within a year The Hon’ble Supreme Cour case has also observed that ‘consolidation of FIRs that would depend upon the conclusion to be arrived at after As per Hon’ble Supreme Court of India, in the above procedure was adopted by the Delhi Police in registering one FIR and treating the complaint received from 1851 other complainants as statements under Section 161 CrPC. According to Hon’ble Supreme Court of India, the inference to be drawn from the charge-sheets, as filed, would be left to the Judicial Magistrate concerned to consider, so as to various acts of cheating attributed to the accused persons constitute part of the same transaction, thereby bringing the 220(1) CrPC and Section 223(a) & (d) CrPC Supreme Court of India, if the offence formed 9 ourt of India, the abovementioned tests may be applied to ascertain whether a series of acts form part of the same transaction or not. It is not necessary at the present stage to consider whether consolidation of charges under Section 220(1) CrPC should be resorted to, as that would depend upon the opinion of the Magistrate on the d during the investigation. If it is opined that all the incidents partake of the same transaction, there can be one trial under Section 220(1) CrPC and Section 223(a) and 223(d) CrPC. If, however, it is concluded that there are several transactions and distinct offences in relation to different victims, there have to be separate trials for each offence, subject to Section 219 CrPC/ Section 242 BNSS, which allows the Trial Court to try three/five offences of the same kind committed within a year’. ’ble Supreme Court of India in the abovementioned ‘consolidation of FIRs is permissible in law, but upon the conclusion to be arrived at after investigation’. As per Hon’ble Supreme Court of India, in the abovementioned case, a right procedure was adopted by the Delhi Police in registering one FIR and from 1851 other complainants as statements . According to Hon’ble Supreme Court of India, the sheets, as filed, would be left to the Judicial Magistrate concerned to consider, so as to ascertain whether the various acts of cheating attributed to the accused persons constitute part of , thereby bringing them within the ambit of Section 220(1) CrPC and Section 223(a) & (d) CrPC. As directed by the Hon’ble Supreme Court of India, if the offence formed part of the same transaction, abovementioned tests may be applied to ascertain whether a series of acts form part of the same transaction or not. It is not necessary at the present stage to consider whether consolidation of charges under Section 220(1) CrPC should be resorted to, as that would depend upon the opinion of the Magistrate on the d during the investigation. If it is opined that all the incidents partake of the same transaction, there can be one trial under (d) CrPC. If, however, it is nct offences in relation to different victims, there have to be separate trials for each offence, subject to Section 219 CrPC/ Section 242 BNSS, which allows the Trial Court to try in the abovementioned is permissible in law, but investigation’. mentioned case, a right procedure was adopted by the Delhi Police in registering one FIR and from 1851 other complainants as statements . According to Hon’ble Supreme Court of India, the sheets, as filed, would be left to the whether the various acts of cheating attributed to the accused persons constitute part of m within the ambit of Section . As directed by the Hon’ble part of the same transaction, GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document the Judicial Magistrate would be entitled to charge and try them together, as enabled by the aforesaid provisions, as it would be in the larger public interest to do so. 20. Court of India & Ors.’, abovemen has been held by this Court that multiplicity of proceedings will not be in larger public interest. Further, since many States have invoked local Acts, particulars the Act dealing with the Protection of Interest of Depositors, transferring them out of the State also will not serve the ends of justice. Hence, the correct course of action would be to merge the FIRs with the earliest FIR in the State concerned 21. India has allowed the writ petition CRM-M-5177-2026 (O&M) the Judicial Magistrate would be entitled to charge and try them together, as abled by the aforesaid provisions, as it would be in the larger public interest to do so. Similar question has been dealt with by the Hon’ble Supreme Court of India in the case of ‘Ravinder Singh Sidhu Writ Petition (Crl) No.394 of 2024, it has been observed ntioned case that ‘the law in this issue is now fairly well settled. It has been held by this Court that multiplicity of proceedings will not be in larger public interest. Further, since many States have invoked local Acts, iculars the Act dealing with the Protection of Interest of Depositors, transferring them out of the State also will not serve the ends of justice. Hence, the correct course of action would be to merge the FIRs with the earliest FIR in the State concerned’. In the abovementioned case, the Hon’ble Supreme Court of India has allowed the writ petition in the f “while the first FIR will be treated as the First Information Report (hereinafter for convenience called the ‘principal FIR’), the subsequent FIRs in each State shall be treated as Statements under Section 161 of the Code of Criminal Procedure, 1973 (CrPC). The Investigating Officer in the criminal case arising out of the principal FIR in the concerned State will be free to file supplementary charge collation of all records concerning other FIRs in the concerned State which are clubbed in terms of this order. We further direct that if Police Report under Section 173 of CrPC stands already filed in the clubbed FIRs a have taken cognizance thereof, the said FIR and criminal cases 10 the Judicial Magistrate would be entitled to charge and try them together, as abled by the aforesaid provisions, as it would be in the larger public Similar question has been dealt with by the Hon’ble Supreme in the case of ‘Ravinder Singh Sidhu V/s The State of Punjab rl) No.394 of 2024, it has been observed in the law in this issue is now fairly well settled. It has been held by this Court that multiplicity of proceedings will not be in larger public interest. Further, since many States have invoked local Acts, iculars the Act dealing with the Protection of Interest of Depositors, transferring them out of the State also will not serve the ends of justice. Hence, the correct course of action would be to merge the FIRs with the In the abovementioned case, the Hon’ble Supreme Court of following words:- “while the first FIR will be treated as the First Information Report (hereinafter for convenience called the ‘principal FIR’), he subsequent FIRs in each State shall be treated as Statements under Section 161 of the Code of Criminal Procedure, 1973 (CrPC). The Investigating Officer in the criminal case arising out of the principal FIR in the concerned pplementary charge-sheets after the collation of all records concerning other FIRs in the concerned State which are clubbed in terms of this order. We further direct that if Police Report under Section 173 of CrPC stands already filed in the clubbed FIRs and the concerned Courts have taken cognizance thereof, the said FIR and criminal cases the Judicial Magistrate would be entitled to charge and try them together, as abled by the aforesaid provisions, as it would be in the larger public Similar question has been dealt with by the Hon’ble Supreme V/s The State of Punjab the the law in this issue is now fairly well settled. It has been held by this Court that multiplicity of proceedings will not be in larger public interest. Further, since many States have invoked local Acts, iculars the Act dealing with the Protection of Interest of Depositors, transferring them out of the State also will not serve the ends of justice. Hence, the correct course of action would be to merge the FIRs with the In the abovementioned case, the Hon’ble Supreme Court of “while the first FIR will be treated as the First Information Report (hereinafter for convenience called the ‘principal FIR’), he subsequent FIRs in each State shall be treated as Statements under Section 161 of the Code of Criminal Procedure, 1973 (CrPC). The Investigating Officer in the criminal case arising out of the principal FIR in the concerned sheets after the collation of all records concerning other FIRs in the concerned State which are clubbed in terms of this order. We further direct that if Police Report under Section 173 of CrPC stands nd the concerned Courts have taken cognizance thereof, the said FIR and criminal cases GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document 22. Special Leave to Appeal (Crl.) No.4073/2025, the Hon’ble Supreme Court of India recorded the following observations: 23. law, which are applicable to the facts and circumstances of the present case and the fact that all the to transactions with the same Society is hereby all the FIRs to District Panipat and the oldest FIR, too, belongs to District Panipat, it is hereby ordered that all the FIRs/cha (viii) and No.449 dated 12.11.2024 shall serve as principal FIR and all the subsequent complaints/FIRs shall be treated as the statement of complainants under CRM-M-5177-2026 (O&M) would also stand transferred and merged/clubbed along with the principal FIR to be proceeded with in accordance with law.’ In the case of ‘Alok Kumar V/s The State Special Leave to Appeal (Crl.) No.4073/2025, the Hon’ble Supreme Court recorded the following observations: ‘the first thing that we should do is to order clubbing of all the 81 FIRs/criminal cases registered against the petition We direct that the very first FIR registered against the petitioner dated 11.01.2018 with the Shashtri Nagar Police Station, Patna, Bihar shall be treated as the main FIR. All other First Information Reports shall be treated as statements under Section 161 of the Criminal Procedure Code, 1973 (for short “the CrPC”). We are passing this order in tune with the decision of this Court in the case of “Satinder Singh Bhasin v. State of U.P. and Another” reported in 2023 (14) SCC 805.’ Taking into consideration the abovementioned principles of law, which are applicable to the facts and circumstances of the present case and the fact that all the FIRs against the petitioner are emanating with regard to transactions with the same Society rega is hereby observed that in the given fact-s all the FIRs are clubbed together. Since the District Panipat and the oldest FIR, too, belongs to District Panipat, it is hereby ordered that all the FIRs/charge-sheets and (ix) in the table, shall stand transferred to Panipat and the FIR No.449 dated 12.11.2024 shall serve as principal FIR and all the subsequent complaints/FIRs shall be treated as the statement of complainants under 11 would also stand transferred and merged/clubbed along with the principal FIR to be proceeded with in accordance with In the case of ‘Alok Kumar V/s The State of Bihar & Ors.’ Special Leave to Appeal (Crl.) No.4073/2025, the Hon’ble Supreme Court recorded the following observations:- that we should do is to order clubbing of all the 81 FIRs/criminal cases registered against the petitioner. We direct that the very first FIR registered against the petitioner dated 11.01.2018 with the Shashtri Nagar Police Station, Patna, Bihar shall be treated as the main FIR. All other First Information Reports shall be treated as statements under on 161 of the Criminal Procedure Code, 1973 (for short “the CrPC”). We are passing this order in tune with the decision of this Court in the case of “Satinder Singh Bhasin v. State of U.P. and Another” reported in 2023 (14) SCC 805.’ sideration the abovementioned principles of law, which are applicable to the facts and circumstances of the present case against the petitioner are emanating with regard arding similar type of allegations, it situation, it shall be appropriate t clubbed together. Since the highest number of FIRs pert District Panipat and the oldest FIR, too, belongs to District Panipat, it is sheets detailed at Sr. No.(vi), (vii transferred to Panipat and the FIR No.449 dated 12.11.2024 shall serve as principal FIR and all the subsequent complaints/FIRs shall be treated as the statement of complainants under would also stand transferred and merged/clubbed along with the principal FIR to be proceeded with in accordance with of Bihar & Ors.’ Special Leave to Appeal (Crl.) No.4073/2025, the Hon’ble Supreme Court that we should do is to order clubbing of all the We direct that the very first FIR registered against the petitioner dated 11.01.2018 with the Shashtri Nagar Police Station, Patna, Bihar shall be treated as the main FIR. All other First Information Reports shall be treated as statements under on 161 of the Criminal Procedure Code, 1973 (for short “the CrPC”). We are passing this order in tune with the decision of this Court in the case of “Satinder Singh Bhasin v. sideration the abovementioned principles of law, which are applicable to the facts and circumstances of the present case against the petitioner are emanating with regard lar type of allegations, it that tain District Panipat and the oldest FIR, too, belongs to District Panipat, it is vii), transferred to Panipat and the FIR No.449 dated 12.11.2024 shall serve as principal FIR and all the subsequent complaints/FIRs shall be treated as the statement of complainants under GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document Section 161 already been filed, the abovementioned charge supplementary charge 24. 25. allowed, a 26. disposed of, accordingly. 21.04.202 Gaurav Thakur CRM-M-5177-2026 (O&M) Section 161 of CrPC. If charge-sheet in an already been filed, the abovementioned charge supplementary charge-sheet in the main case. For rest of the prayers, the in With these observations, th accordingly. Pending miscellaneous application(s), if any, shall also stand disposed of, accordingly. 2026 Gaurav Thakur Whether speaking / reasoned Whether Reportable 12 ny of the abovementioned cases already been filed, the abovementioned charge-sheet shall be treated as sheet in the main case. nstant petition is hereby dismisse he present petition stands par Pending miscellaneous application(s), if any, shall also stand (SURYA PARTAP SINGH) JUDGE Whether speaking / reasoned Yes/No Yes/No cases has sheet shall be treated as ed. rtly Pending miscellaneous application(s), if any, shall also stand ) GAURAV THAKUR 2026.04.24 19:59 I attest to the accuracy and integrity of this document