The Supreme Court on Friday (September 26) ruled that nationwide consolidation of FIRs involving different witnesses, evidence, and local laws is impermissible, clarifying that such clubbing is allowed only when multiple FIRs stem from the same incident or transaction.

A bench of Chief Justice of India BR Gavai and Justice K. Vinod Chandran declined to merge several FIRs filed across different States against the Appellant in a multi-crore financial scam. The Court emphasized that each FIR involved distinct facts, witnesses, and legal provisions, making nationwide consolidation unworkable.

The Appellant had relied on Amish Devgan v. Union of India (2021), where FIRs were consolidated since they arose from a single televised statement. However, Justice Chandran, writing for the Bench, distinguished the two cases, noting:

“In Amish Devgan, the offence alleged was a single objectionable statement on a television broadcast, leading to multiple FIRs on the same cause of action. By contrast, in the present case, FIRs have been filed by different investors and depositors claiming they were cheated by diversion of funds. Each complaint involves separate victims and evidence. Once chargesheets are filed, trials would require producing investor-witnesses from different locations. In such circumstances, nationwide clubbing of FIRs is impractical.”

While rejecting pan-India consolidation, the Court permitted State-wise clubbing of FIRs. In Telangana, four FIRs were registered—three before the Economic Offences Wing (EOW), Cyberabad, and one at Madhapur, Cyberabad. The Court directed that the Madhapur FIR be transferred to the EOW. Similarly, in Maharashtra, two FIRs existed—one at Ambazari, Nagpur City, and another at Wagle Estate, Thane City. The Court ordered FIR No. 210/2025 at Wagle Estate to be transferred to Ambazari.

The Court, however, refused to consolidate the single FIRs filed in Karnataka, West Bengal, Delhi, Andhra Pradesh, and Rajasthan.

Disposing of the petition, the Court held that FIRs may be clubbed only within the same State, not across States.

Case Title: Odela Satyam & Anr. v. State of Telangana & Ors.