2026 Supreme(SC) 555

SUPREME COURT OF INDIA
Pankaj Mithal, Prasanna B. Varale, JJ.
Amit Katyal & Anr. – Petitioners
Versus
State Of Haryana & Anr. – Respondents
Writ Petition (Crl.) No. of 67 of 2025
Decided On : 18-05-2026

Permitting multiple parallel criminal investigations for the same occurrence violates established procedural law. A unified investigation prevents institutional conflict, ensures judicial consistency, avoids multiple proceedings for the same act, and upholds the accused's right to defend themselves effectively in a single, coordinated process.

Headnote:(A) Constitution of India - Article 32 - Code of Criminal Procedure - Sections 154, 156, 157, 162, 169, 170 and 173 - Penal Code - Sections 406, 420 and 120B - Multiple First Information Reports regarding the same transaction - Allegations of cheating and criminal breach of trust in real estate developments - Principles regarding registration of multiple FIRs for the same incident - Settled legal position that there cannot be a second FIR for the same occurrence - Requirement of a single, comprehensive investigation to facilitate coordinated legal enquiry - Consolidation of proceedings to avoid multiplicity, conflicting findings, and prejudice to the accused - Right of accused to fair trial and effective defence. (Paras 21, 24, 25, 26)

Facts of the case:
The petitioners sought the transfer and clubbing of multiple criminal proceedings registered in different jurisdictions arising from the same set of transactions pertaining to a real estate project. The petitioners argued that the persistent registration of separate criminal cases for identical allegations of non-delivery of properties and misappropriation of funds caused undue prejudice and infringed upon their fundamental rights by exposing them to potential double jeopardy and parallel litigation.

Findings of Court:
The court observed that the core allegations in the various criminal cases pertained to the same set of project transactions, making the registration of multiple separate cases for the same occurrence legally untenable under the existing statutory scheme. The court emphasized that the law allows for a single, comprehensive investigation with the liberty to file supplementary reports, rather than permitting disjointed investigations across different regional bodies.

Issues: The central questions addressed were whether multiple criminal proceedings initiated in different locations regarding the same series of real estate transactions are legally permissible and whether such proceedings should be consolidated to ensure a singular, fair investigation.

Ratio Decidendi: The court held that law forbids the registration of subsequent FIRs for the same transaction. A unified investigation prevents institutional conflict, promotes judicial efficiency by avoiding contradictory findings, and protects the accused from the prejudice caused by multiplicity of proceedings. The consolidation of investigations is necessary to serve the ends of justice and safeguard the right of the accused to defend themselves against a single set of interconnected allegations.

Result: Petitioners' requests for consolidation are granted; the proceedings are directed to be clubbed. The request for a blanket restraint on future criminal complaints is denied, leaving open appropriate legal remedies for the petitioners.