SUPREME COURT OF INDIA
Sanjay Karol, Augustine George Masih, JJ.
Rutvij Bhagat Singh Wakhare – Petitioner
Versus
The State Of Maharashtra & Ors. – Respondents
Writ Petition (Crl.) No. 127 of 2026
Decided On : 24-07-2026

Extraordinary constitutional jurisdiction for quashing criminal proceedings is reserved for exceptional cases; consolidation of multiple complaints requires meeting the test of a single transaction, absent which, separate trials must proceed for distinct offences and victims.

Headnote:(A) Constitution of India - Article 32 - Quashing of criminal proceedings - When a petition is filed invoking extraordinary constitutional jurisdiction for quashing criminal complaints, the court must consider whether exceptional circumstances or violations of fundamental rights necessitate bypassing alternate legal remedies available in subordinate jurisdictions. (Paras 6-10)

(B) Criminal Procedure - Multiple proceedings - Consolidation - Clubbing of separate complaints is impermissible when the events involve distinct victims, disparate transactions, and separate consequences, even if the underlying methods of operation appear similar; unity of purpose, proximity of time/place, and continuity of action are essential to meet the test for the same transaction. (Paras 12-16)

Facts of the case:
The petitioner sought to quash several criminal complaints lodged across multiple jurisdictions regarding alleged cyber-fraud, or alternatively, to consolidate these proceedings into a single composite investigation. The petitioner contended that his business account was misused by third parties and that he had no involvement in the reported illicit transfers.

Findings of Court:
The court determined that the petitioner failed to demonstrate any violation of fundamental rights or exceptional circumstances that would justify the direct exercise of its extraordinary jurisdiction. It further held that each complaint documented distinct events involving different complainants, thereby precluding the consolidation of the proceedings.

Issues: Whether an extraordinary constitutional remedy is appropriate for the mass quashing of criminal proceedings, and whether multiple complaints initiated in diverse jurisdictions can be merged into a single investigation based on a similar pattern of illegal activity.

Ratio Decidendi: Jurisdiction under the constitutional writ power should be exercised sparingly, with the requirement that petitioners first exhaust available remedies in lower courts unless a clear breach of fundamental rights is established. Regarding the consolidation of proceedings, the 'test of sameness' requires that incidents form a single, continuous transaction; here, the lack of linkage between distinct victims and separate financial transactions rendered the request for consolidation legally untenable.

Result: Writ petition dismissed with liberty to the petitioner to pursue appropriate remedial measures in the relevant subordinate courts.