Paragraph numbers below are the court’s original numbering, recovered from the source text.
10. Heard learned Senior Counsel/Counsel for the parties. 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). [See Radhey Shyam v. State of Haryana and Ors., 2022 SCC OnLine SC 1935 and Abhishek Singh Chauhan v. Union of India and Ors., 2022 SCC OnLine SC 1936].
11. We propose to follow the said course of action. In view of the above in the State of Gujarat, the following 3 FIRs will now be merged with FIR No. I-79/2018 dated 27.09.2018 registered at Bhavnagar Gangajaliya. [2025] 5 S.C.R. Ravinder Singh Sidhu v. The State of Punjab & Ors. Sr. No. FIR No. Date Police Station Place 1. I-92/2018 26.11.2018 Bhavnagar Gangajaliya 2. I-293/2018 18.11.2018 P.S. Vadaj Ahmedabad City 3. I-285/2018 14.11.2018 P.S. Vadaj Ahmedabad City
12. In the State of Haryana, the following 5 FIRs will now be merged with FIR No. 24/2018 dated 16.01.2018 registered at Ambala P.S. Ambala Cant. Sr. No. FIR No. Date Police Station Place 1. 98/2019 04.04.2019 Bhiwani Civil Lines Bhiwani 2. 167/2022 01.08.2022 Raipur Rani Panchkula 3. 235/2021 21.05.2021 Hisar City Hisar 4. 1015/2018 09.10.2018 Sirsa City Sirsa 5. 503/2019 COMI No. 110/2020) NA Narnaul Narnaul
13. In the State of Himachal Pradesh, the following FIR will now be merged with FIR No. 13/2019 registered at Hamirpur, P.S. Sujanpur Tira. Sr. No. FIR No. Date Police Station Place 1. 202/2019 09.12.2019 Jawali Kangra
14. In the State of Madhya Pradesh, the following FIR will now be merged with FIR No. 496/2018 dated 05.12.2018 registered at Jabalpur P.S. Lordganj. 2654 Sr. No. FIR No. Date Police Station Place 1. 176/2020 24.05.2020 Kotwali Anuppur Anuppur
15. In the State of Punjab, the following 16 FIRs will now be merged with FIR No. 198/2018 dated 23.10.2018 registered at SAS Nagar, P.S. Phase I. Sr. No. FIR No. Date Police Station Place 1. 183/2020 12.08.2020 Dasuya Hoshiarpur 2. 62/2021 21.04.2021 Dasuya Hoshiarpur 3. 291/2020 16.12.2020 Dasuya Hoshiarpur 4. 81/2021 21.04.2021 City Gurdaspur Gurdaspur 5. 151/2021 04.08.2021 City Hoshiarpur Hoshiarpur 6. 280/2020 12.12.2020 City Hoshiarpur Hoshiarpur 7. 30/2022 04.03.2022 Anaj Mandi Patiala 8. 55/2021 23.05.2021 Talwara Hoshiarpur 9. 99/2021 20.05.2021 Talwara Hoshiarpur 10. 64/2021 20.05.2021 City Batala Batala (Gurdaspur) 11. 141/2019 02.09.2019 City Gurdaspur Gurdaspur P.S. 12. 0043/2019 12.02.2019 City Tarn Taran Tarn Taran 13. 07/2021 16.01.2021 City Hoshiarpur 14. 53/2021 29.03.2021 City Hoshiarpur 15. 05/2024 06.03.2024 N.R.I. Amritsar 16. 144/2024 29.10.2024 Kotwali Bathinda [2025] 5 S.C.R. Ravinder Singh Sidhu v. The State of Punjab & Ors.
16. In the State of Rajasthan, the following 3 FIRs will now be merged with FIR No. 878/2018 dated 20.11.2018 registered at Karauli P.S. Hindon. Sr. No. FIR No. Date Police Station Place 1. 125/2019 06.06.2019 Tibbi Hanumangarh 2. 90/2019 12.03.2019 Bhupalpura Udaipur 3. 292/2019 05.08.2019 Vidhayakpuri Jaipur City (South)
17. In the State of Uttar Pradesh, the following 14 FIRs will now be merged with FIR No. 28/2019 dated 13.01.2019 registered at Basti P.S. Kotwali. Sr. No. FIR No. Date Police Station Place 1. 82/2019 09.02.2019 Hari Parvat Agra 2. 303/2019 25.06.2019 Aonla Bareilly 3. 617/2020 25.12.2020 Nawabad Jhansi 4. 33/2019 15.03.2019 Harbans Mohal East (Commissionerate Kanpur City) 5. 55/2019 11.05.2019 Harbans Mohal East (Commissionerate Kanpur City) 6. 57/2019 14.05.2019 Harbans Mohal East (Commissionerate Kanpur City) 7. 480/2020 Sungarhi Pilibhit 8. 409/2019 Sungarhi Pilibhit 9. 119/2019 15.02.2019 Sigra Kashi (Commissionerate Varanasi) 10. 189/2019 29.05.2019 Bhadohi Bhadohi 11. 406/2019 19.05.2019 Cantt Gorakhpur 12. 361/2019 18.06.2019 Sigra Varanasi 13. 463/2019 23.10.2019 Sigra Varanasi 14. 280/2022 Bareilly Faridpur 2656
18. In the State of Uttarakhand, the following 4 FIRs will now be merged with FIR No. 107/2018 dated 30.10.2018 registered at Pithoragarh P.S. Kotwali Pithoragarh. Sr. No. FIR No. Date Police Station Place 1. 165/2019 24.08.2019 Mukhani Nainital 2. 30/2019 07.07.2019 Lohaghat Champawat 3. 44/2019 19.02.2019 Jaspur Udham Singh Nagar 4. 86/2024 24.04.2024 Mukhani Nainital
19. The writ petition stands allowed in the above terms. We further direct 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- 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 FIRs and criminal cases would also stand transferred and merged/clubbed along with the principal FIR to be proceeded with in accordance with law.
20. The investigating officer in the principal proceedings will be free to file supplementary charge-sheet on the basis of the material collated during investigation of other FIRs. We also make it clear that the other offences not part of the special enactments can also be tried by the Special Court under the concerned State legislation. We also further direct that in case the petitioner has been granted bail in connection with the principal proceeding/criminal case to which the other cases have been clubbed, the bail so granted must enure to the petitioner’s favour in the other FIRs now clubbed as well. We further clarify that if the principal FIR is limited to offence under the general law/Penal Code but the subsequent FIRs contain allegations [2025] 5 S.C.R. Ravinder Singh Sidhu v. The State of Punjab & Ors. attracting offences under the special enactment or certain other IPC offences and if the bail granted is only for some offences under the general law, the Special Court is entitled to insist for a fresh bail application to be filed by the petitioner in relation to those offences including under the Special Act. The said bail application(s) shall be decided on its own merits in accordance with law.
21. We make it clear that our direction is confined to the offences mentioned in the present order, namely, the offences under the IPC and the concerned State enactment mentioned herein.
22. As far as the State of Chhattisgarh and NCT of Delhi are concerned, since there is only one case each, the said case will proceed in those States in accordance with law and the question of clubbing does not arise. We have passed the above order in exercise of powers under Article 32 read with our powers under Article 142 of the Constitution of India. Result of the case: Writ Petition allowed. †Headnotes prepared by: Aishani Narain, Hony. Associate Editor (Verified by: Nidhi Jain, Editor)