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2025 Supreme(Telangana) 57

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
T. VINOD KUMAR, J.
Chavva Kumar - Appellant
Versus
The State of Telangana Home - Respondent
W.P.No. 14867 of 2025
Decided On : 09-06-2025

Advocates:
Advocate Appeared:
For the Appellant : KATIKA RAVINDER REDDY
For the Respondent: GP FOR HOME

The court affirmed that multiple FIRs can be registered for distinct complaints arising from separate transactions, which do not constitute a violation of legal principles against multiple registrations.

Headnote:(A) Constitution of India - Articles 14 and 21 - Registration of multiple FIRs - Petitioners contended that FIRs being registered against them are illegal as they arise from the same incident covered by prior FIR. Court considered each FIR represents distinct complaints with different grievances, thus validating the authorities’ actions in registering multiple FIRs. (Paras 3, 13, 19)

(B) Judicial Precedents - Court referred to previous decisions: Jakir Hussain Kosangi v. State of Andhra Pradesh, AIR 2020 SC 2386, and State of Rajasthan v. Surendra Singh Rathore, 2025 INSC 248 for principles regarding multiple FIRs. (Paras 14, 15, 16)

Facts of the case:
The petitioners argued against multiple FIRs regarding different complainants alleging similar offenses of cheating and criminal breach of trust linked to separate transactions. (Paras 3, 4, 10)

Findings of Court:
The Court found that the complaints registered were based on a series of independent transactions, thus justifying multiple FIR registrations. (Paras 13, 19)

Issues: The core issue was whether multiple FIRs could be registered for distinct grievances out of separate transactions leading to further investigation.

Ratio Decidendi: The court ruled that FIRs arising from different transactions do not violate the principle against multiple FIRs being registered. The claims of the petitioners were rejected as no single event could be identified in the multiple complaints. (Paras 12, 20)

Result: Writ Petition dismissed.

Table of Content
1. illegal registration of multiple firs. (Para 3 , 4 , 5)
2. firs based on separate allegations upheld. (Para 6 , 7 , 8 , 9 , 10 , 11)
3. different grievances from different complainants. (Para 12 , 13 , 17 , 18 , 19)
4. criteria for multiple fir registration. (Para 14 , 15 , 16)
5. writ petition dismissed. (Para 20 , 21)

ORDER :

T. VINOD KUMAR, J.

Heard learned counsel for the petitioners, learned Government Pleader for Home appearing for respondent Nos.1 to 7, and with their consent the Writ Petition is taken up for hearing and disposal at admission stage.

2. Having regard to the manner of disposal of the writ petition and the nature of lis involved, this Court is of the view that notice to unofficial respondent Nos.8 to 11 is not necessary for adjudication of the present Writ Petition

3. The case of the petitioners, in brief, is that respondent Nos.2 to 7 are registering multiple FIRs on the file of the 5th respondent-Police Station in respect of the same transaction/incident covered by FIR.No.193/2018, which action of the respondents is illegal, arbitrary and violative of Article 14 & 21 of the Constitution of India.

4. Petitioners further contends that as the respondents- authorities having already registered a case vide FIR.No.193/2018, the authorities ought to not to have registered further crime as the same arise out of the same transaction/incident, and on the other hand, the respondents-authorities ought to have treated the complaint given by the other complainants as statements under Section 161 of Cr.P.C., while investigating into the first crime registered vide FIR.No.193/2018.

5. On behalf of the petitioners it is further contended that after registering multiple FIRs, all the cases have been transferred to CID, and as such, all the FIRs should have been clubbed together without registering further FIRs against the petitioners herein.

6. Per contra, learned Government Pleader appearing on behalf of respondents-authorities would submit that initially case vide FIR.No.193/2018, dt.06.06.2018, has been registered against the petitioners herein basing on the complaint made by one Ch.Mallesh and another, claiming that the petitioners having lured him to invest money and that he would be paid interest @ Rs.1.50 paisa per Rs.100/-, and basing on the aforesaid promise, the complainant therein having deposited an amount of Rs.7 lakhs with the petitioners herein.

7. Learned Government Pleader would further submit that thereafter similar such complaints have been received against the petitioners of resorting to criminal breach of trust and cheating, from the unofficial respondents herein; and that the authorities based on the said complaints have registered the other FIRs viz., FIR.Nos.212, 213 and 337 of 2022.

8. Learned Government Pleader would further submit that each of the complainant by complaint lodged by them have claimed of the petitioners having cheated them of different amounts, and for the said reason, the authorities have registered different crimes and are investigating the same.

9. Learned Government Pleader would further submit that having regard to the serious nature of the complaints, the authorities have transferred the investigation of all the FIRs to CID, and the matter is being investigated into by the concerned CID authorities.

10. Learned Government Pleader would also submit that though the petitioners claim of the transactions/incidents to be the one and as such the authorities ought to be restrained from registered multiple FIRs and being investigated into independently, said claim cannot be accepted for the reason that, each of the incident/transaction is an independent transaction and does not arise out of a single transaction, for the petitioners to seek the aforesaid relief.

11. Learned Government Pleader would further submit that each of the complainants have made out a specific case against the petitioners, and since, the facts in each case are different, the action of the respondents-auth

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