New Delhi, September 26, 2025 — The Supreme Court of India has rejected a plea by several accused persons seeking to merge multiple First Information Reports (FIRs) filed against them across different states in connection with an alleged financial fraud. The Court, however, permitted limited consolidation of cases within the same state to prevent duplication of investigation.
The petitions were filed by partners and directors of a firm accused of duping investors across India. FIRs were registered in Telangana, Maharashtra, Karnataka, West Bengal, Delhi, Andhra Pradesh, and Rajasthan, alleging defalcation of funds collected from unsuspecting depositors.
What the Petitioners Sought
The accused had asked the Court to:
- Club all FIRs from different states into one investigation.
- Prevent future FIRs on the same cause of action.
They argued that the allegations were essentially the same, and multiple investigations caused undue hardship.
Supreme Court’s Observations
A Bench led by Justice K. Vinod Chandran held that the request to consolidate FIRs across states was “overambitious and outright illegal.” Citing previous rulings, the Court noted that while duplicate FIRs for the same incident are impermissible, distinct crimes involving separate victims and transactions cannot be collapsed into one case.
The Court emphasized that unlike cases involving a single statement or event (such as in the Amish Devgan case concerning allegedly offensive remarks on TV), this fraud involved numerous investors from different states. Each complaint had unique facts and local legal provisions, making nationwide consolidation impractical.
Limited Relief Granted
The Court allowed only intra-state consolidation:
- In Telangana, four FIRs were pending; one filed at Madhapur was transferred to the Economic Offences Wing, Cyberabad.
- In Maharashtra, two FIRs were pending; the case from Thane was transferred to Nagpur.
Requests to club FIRs from Karnataka, West Bengal, Delhi, Andhra Pradesh, and Rajasthan were rejected.
Bail and Protection from Arrest
Noting that some petitioners had already spent months in jail, the Court granted them interim bail, subject to conditions set by jurisdictional magistrates. Others facing arrest warrants were also granted six months’ protection from coercive action. During this period, they must apply for regular bail before the respective courts. Failure to cooperate with investigations could lead to cancellation of bail.
Key Takeaways
- Nationwide consolidation of FIRs is not permissible, especially in multi-victim, multi-state frauds.
- Intra-state consolidation may be allowed to streamline investigation.
- Accused persons have been given temporary protection to seek regular bail.
The judgment underscores the Court’s balancing act: preventing undue harassment of accused through multiple overlapping FIRs, while safeguarding the rights of victims spread across the country.
PDF of Odela Satyam Versus The State of Telangana Writ Petition (Criminal) No. of 2025 [@Diary No.26673 of 2025] 2025 INSC 1174