INTRODUCTION
In the case of Odela Satyam & Anr. v. State of Telangana & Ors., W.P. (Crl.) D.No.26673 of 2025, Supreme Court [2025 INSC 1174], the complainants petitioned that a large number of registered FIRs in other states alleging the commission of Financial Fraud, should be consolidated into a single FIR. This was based on their reasoning that the offences alleged had a common modus operandi and the alleged offences should be investigated by the same police station to avoid harassment and multiple investigation processes. This petition was dismissed by the Supreme Court which held the view of clubbing FIRs Action or Transactions originated in different States is not legal, however FIRs can be consolidated in the same State and transferred to one police station for subsequent investigation.
BACKGROUND
1. Legal basis for FIRs- Under Section 154 of the Code of Criminal Procedure, 1973 (CrPC), FIRs have to be registered as soon as information is received of cognizable offence. FIRs trigger investigations, and are based on the jurisdiction of that police station. Each FIR can only have one cause of action, but a single FIR can cover multiple offences arising from a single event.
2. Practical considerations with multiple FIRs- In cases involving fraud across the country, speeches, advertisements, or online publications FIRs are often registered in many different States. Typically petitioners wish for clubbing of FIRs so they don’t have to travel long distance for multiple hearings, avoid duplication of proceedings and keep from being harassed by further proceedings. The victim wishes to pursue the complaint locally!
- Past Court Cases- The developments of jurisprudences on the issue have been uneven over a span of twenty years:
T.T. Antony v. State of Kerala, (2001) 6 SCC 181
It was held there could be cannot be a second FIR with respect to the same incident – all subsequent information should be treated as a statement under Section 162 CrPC.
Upkar Singh v. Ved Prakash, (2004) 13 SCC 292
The Court clarified that counter complaints were not proscribed and T.T. Antony only precluded filing multiple FIRs in respect of the same incident/occurrence by the same party.
Arnab Ranjan Goswami v. Union of India, (2020) 14 SCC 12
There were multiple FIRs against a journalist with respect to the same broadcast on television. The FIRs were clubbed together by the Court as they related to one telecast of the news.
Amish Devgan v. Union of India, (2021) 1 SCC 1
A hate speech case where multiple FIRs were lodged on the same matter in different States. The Court did not quash the FIRs on the basis each FIR was on behalf of different complainants in different States. However, for convenience some FIRs were transferred in the jurisdiction of the first FIR.
Radhey Shyam v. State of Haryana, W.P. (Crl.) No.75 of 2020 (Order dated 12.05.2022)
The Court permitted clubbing of FIRs under Article 142 of the Constitution only because all States involved had agreed to club. -
KEYPOINTS
- 1. Pan-India clubbing rejected- Court characterized a motion to club FIRs from multiple States and even “future FIRs” as overly ambitious and totally illegal. Territorial jurisdiction of States may not be avoided.
2. Clubbing is only allowed within the State- In Telangana 4 FIRs is clubbed under the Economic Offences Wing. Maharashtra has 2 FIRs lubbed under Ambazari, Nagpur City Police Station. All other States – FIRs in Karnataka, West Bengal, Delhi, Andhra Pradesh and Rajasthan were independent.
3. Difference from Amish Devgan case- In it, the multiple FIRs arose from a single TV debate telecast. So the FIRs were designed as one incident. In Odela Satyam, the FIRs were based on a separate complaint by different investors who suffered separate losses but were based on the same modus operandi. Therefore a different factual cause of action in each FIR.
4. BNSS 2023 and joint trial- The Court cited section 242 of the Bharatiya Nagarik Suraksha Sanhitha, 2023 (BNSS), which contemplates the clubbing of up to five offences of the same kind which occurred within a period of twelve months for a single trial. The BNSS only comes into play at the time of trial and within one jurisdiction, not the time of investigation over multiple States.
5. Remedies Against Harassment- The Court balanced the need for pan-India consolidation and recognised the inconvenience of multiple prosecutions. It granted interim bail for six months to the arrested petitioners on the condition that they cooperated. Temporary protection was assured to those who faced pending warrants if they sought bail in the appropriate jurisdiction within six months.
6. Future FIRs- As a matter of law, the request for automatic consolidation of future FIRs was rejected as no Court could preemptively resolve a matter which has not yet arisen.
7. Federalism and Jurisdiction- Every State has a constitutional right to investigate offenses that occur within its territory. Clubbing FIRs across States would violate that right and undermine the victim’s rights.
RECENT DEVELOPMENTS
The recent case of Odela Satyam (2025 INSC 1174) has become the authoritative authority clarifying the limits of clubbing FIRs. The case reopined past case law: reaffirming the holding in T.T. Antony, delineating the court’s holding in Amish Devgan in relation to multiple FIRs and limiting the oversight in Radhey Shyam and Amanat Ali. The case also contextualised the new BNSS 2023 provisions, indicating that such provisions would not have the effect of permitting clubbing FIRs across States. Politicians, journalists, and corporate leaders having to deal with multiple FIRs in different states, must face each matter independently. However, within one state, where there are multiple FIRs based on the same or similar facts the court may issue an order to club the FIR and reduce duplication.
CONCLUSION
In Odela Satyam v. State of Telangana (2025 INSC 1174), the Supreme Court has settled the proverbial score over the vexed question of clubbing FIRs. The court indicated that FIRs could be clubbed within the same State when arising out of common scheme or conduct, but that FIRs lodged by different victims or of different causes of action could not exceed State lines. The court also ruled that application of FIRs in future should not, and could not, be precluded by judicial order or merger. This ruling provides an important clarification which meaningfully mediates the competing interests in such cases. On one side, the rights of the accused to be free from the kind of oppression exhibited by repeated or multiple proceedings; on the other side, the rights of victims to obtain their local remedies. This ruling also protects the federal constitutional structure by protecting the prerogatives of the States in the invocation of the investigative power.
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Written by- Anwesha Anant
