Supreme Court: Clubbing of FIRs Allowed Within Same State but Rejected Across States in Crores Investment Fraud Case
Case Name: Odela Satyam & Anr. v. State of Telangana & Ors. (with connected W.P. (Crl.) Nos. 269, 313, 319, 320 & 321 of 2025)
Date of Judgment: September 26, 2025
Citation: 2025 INSC 1174, W.P. (Crl.) D. No. 26673 of 2025
Bench: Hon’ble Chief Justice B.R. Gavai and Hon’ble Mr. Justice K. Vinod Chandran
Held: The Supreme Court partly allowed writ petitions seeking consolidation of multiple FIRs arising out of alleged investor fraud by a financial establishment. It held that clubbing FIRs across different States is impermissible since each offence involves distinct victims, facts, and local laws. However, it permitted transfer of multiple FIRs within the same State to a single police station for consolidated investigation—specifically, FIRs in Telangana were consolidated under the Economic Offences Wing, Cyberabad, and FIRs in Maharashtra were consolidated at Ambazari, Nagpur. It rejected prayers to club future FIRs, terming them overambitious and illegal. The Court also granted interim bail and protection against arrest for six months, directing petitioners to approach jurisdictional courts for regular bail.
Summary: The petitioners, associated with Falcon Invoice Discounting Firm, sought quashing or consolidation of multiple FIRs registered in Telangana, Maharashtra, Karnataka, West Bengal, Delhi, Andhra Pradesh, and Rajasthan. They argued that the FIRs were based on identical allegations of duping investors. The Court, however, distinguished between “same offence” and “similar modus operandi,” holding that each FIR represents a separate crime involving different victims and state-specific deposit protection laws (such as the Telangana Protection of Depositors of Financial Establishments Act, 1999). Relying on T.T. Antony v. State of Kerala (2001), Upkar Singh v. Ved Prakash (2004), Amish Devgan v. Union of India (2021), and Amandeep Singh Saran v. State of Delhi (2023), the Court reiterated that while subsequent FIRs in the same transaction may be treated as statements under Section 162 CrPC, independent offences in different States cannot be clubbed. It clarified that transfer is permissible only intra-State to avoid duplication.
Decision: The Court directed that four FIRs in Telangana be consolidated at the EOW, Cyberabad, and two FIRs in Maharashtra be consolidated at Ambazari, Nagpur, while refusing consolidation of FIRs from other States. It granted interim bail/protection from coercive steps for six months, subject to conditions of cooperation with investigation, and directed petitioners to seek regular bail before jurisdictional courts within that period.