Supreme Court directs clubbing of 64 FIRs state-wise; principal FIR to govern trial and bail entitlements

A Bench of Chief Justice B. R. Gavai and Justice K. V. Viswanathan heard a writ petition filed by Ravinder Singh Sidhu seeking consolidation and transfer of multiple First Information Reports (FIRs) registered against him across several States; while the original prayer for transfer to Panchkula, Haryana was found not maintainable, the petitioner pressed only for consolidation within each State and the Court entertained the petition in special circumstances.

The Court allowed the petition in part and directed state-wise clubbing of FIRs by merging subsequent FIRs with the earliest registered FIR in each State, appointed those earliest FIRs as the “principal FIRs” and laid down consequential procedural directions. The Court emphasised that “multiplicity of proceedings will not be in larger public interest” and clarified the treatment of offences under special enactments. The Court, in its reasoning, observed: “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, 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. Hence, the correct course of action would be to merge the FIRs with the earliest FIR in the State concerned. It is clarified that if the first FIR in the respective States of Gujarat, Haryana, Himachal Pradesh, Madhya Pradesh, Punjab, Rajasthan, Uttar Pradesh and Uttarakhand is 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 Court(s).” The Court further directed that “the subsequent FIRs in each State shall be treated as Statements under Section 161 of the Code of Criminal Procedure, 1973 (CrPC)” and permitted Investigating Officers to file supplementary charge-sheets after collation of records; where police reports under Section 173 CrPC had been filed and cognizance taken, those matters would stand transferred and merged with the principal FIR.

Background

The petition arose from allegations against Ravinder Singh Sidhu, former Managing Director of KIM Infrastructure and Developers Limited (KIDL), in connection with land-allotment schemes and mobilisation of funds under lump-sum and deferred payment plans. Following a writ petition before the Madhya Pradesh High Court, the CBI conducted a preliminary inquiry and SEBI initiated proceedings after KIDL’s attempt to register its scheme as a Collective Investment Scheme was rejected. Investors and agents registered multiple FIRs alleging defaults and a variety of offences.

In all, 64 FIRs across ten States were implicated: Punjab (23), Uttar Pradesh (15), Haryana (6), Uttarakhand (5), Rajasthan (5), Gujarat (4), Madhya Pradesh (2), Himachal Pradesh (2), and one each in Chhattisgarh and NCT of Delhi. Offences related principally to Sections 406, 420, 465, 467, 468, 471 read with Sections 120B, 34, 263 and 114 IPC, and various State enactments including depositor-protection laws and the Prize Chits and Money Circulation Schemes (Banning) Act, 1978. Some trials had concluded (three convictions, two acquittals), two FIRs had cancellation reports, 15 matters were at evidence stage and 21 had charge-sheets filed. The Court declined to disturb completed convictions or acquittals and excluded States with only a single FIR (Chhattisgarh and NCT of Delhi) from clubbing.

Applying settled precedents (including Radhey Shyam v. State of Haryana and Abhishek Singh Chauhan v. Union of India), the Court directed specific mergers: it listed principal FIRs in each State and set out which FIRs were to be merged therewith (for example, Gujarat FIR I-79/2018 as principal for three Bhavnagar/Ahmedabad FIRs; Punjab FIR No. 198/2018 at SAS Nagar as principal for 16 Punjab FIRs; Uttar Pradesh FIR No. 28/2019 at Basti as principal for 14 UP FIRs, and so on). The writ petition stood allowed in the terms recorded.

The Court further ordered that the investigating officer in the principal proceedings could file supplementary charge-sheets based on collated material; if bail had been granted in the principal proceeding, that bail would enure to the petitioner in the clubbed FIRs, subject to the Special Court’s entitlement to require fresh bail applications where offences under special enactments or additional IPC offences arose. The order was passed under Article 32 read with Article 142 of the Constitution.

Case Details: Case No.: WRIT PETITION (CRL.) NO. 394 OF 2024 (2025 INSC 727) Case Title: Ravinder Singh Sidhu v. The State of Punjab & Ors. Appearances: For the Petitioner(s): Senior Counsel for the petitioner (name not indicated in the reported judgment) For the Respondent(s): Counsels for the State respondents (names not indicated in the reported judgment)