Ravi Shankar Tiwari @ Ravi vs State of Madhya Pradesh

Headnote:(A) Code of Criminal Procedure, 1973 - Sections 161, 162 and 173; Bharatiya Nagarik Suraksha Sanhita, 2023 - Sections 180 and 242 - Registration of multiple FIRs for the same cause of action - Subsequent FIRs registered at different places for the same act can be clubbed and proceeded with the principal FIR, treating subsequent FIRs as statements under Section 161 CrPC / 180 BNSS to avoid multiplicity of proceedings, hardship to the accused and witnesses, and the possibility of conflicting judicial findings. (Paras 9 and 11)

(B) Fair Investigative Process - When FIRs emanate from the same transaction or identical allegations, a fair investigative process requires that the entirety of the investigation be consolidated and entrusted to one investigating authority to avoid piece-meal investigation. (Para 10)

Facts of the case:
Members and agents of a cooperative society were subjected to nine subsequent FIRs registered at various police stations across the state for the same act involving the non-payment of maturity amounts to depositors. The petitioners sought the clubbing of these subsequent FIRs with the first registered FIR, including those where the police report had already been filed and cognizance had been taken by the courts.

Findings of Court:
The court observed that the allegations in all the FIRs were identical, as all complainants were aggrieved by the non-payment of maturity proceeds. Clubbing of FIRs and trials is justified to prevent hardship to the accused and witnesses and to avoid the risk of divergent verdicts from different trial courts.

Issues: Whether multiple FIRs registered at different police stations for the same cause of action and identical allegations should be clubbed with the first registered FIR.

Ratio Decidendi: Where the nature of the accusation is identical across multiple FIRs arising from the same transaction, the first FIR should be treated as the principal FIR, and subsequent FIRs should be treated as statements under Section 161 CrPC / 180 BNSS. Consolidation ensures a fair investigative process and judicial consistency.

Result: Petition disposed of with directions to club all subsequent FIRs with the principal FIR and transfer pending trials to the court dealing with the first FIR.

Legal Category Hierarchy

1. Multiple FIRs registered against the same persons for identical allegations of non-payment of depositors' maturity amounts — Relief sought for clubbing of FIRs. (Para 1 , 2 , 6 , 7 , 8 )

2. Petitioner argued hardship and conflicting verdicts from multiple trials; State opposed clubbing citing specific provisions and recent Supreme Court decisions. (Para 3 , 4 )

3. Court applied Supreme Court principles that first FIR should be principal and subsequent FIRs treated as statements under Section 161/162 CrPC. (Para 9 , 10 , 11 )

4. Where multiple FIRs arise from same cause, the first FIR is principal and subsequent FIRs are treated as statements under Section 161 CrPC, clubbable to avoid multiplicity. (Para 11 )

5. Petition disposed directing clubbing of all nine FIRs with principal FIR, and directing police to issue notice instead of arrest on future related complaints. (Para 11 , 12 , 13 )

6. Can multiple FIRs arising from the same cause of action be clubbed together?

Yes, the first FIR is treated as principal and subsequent FIRs as statements under Section 161 CrPC, and they can be clubbed to avoid multiplicity and conflicting findings. (Para 9 , 10 , 11 )

7. Should subsequent FIRs be treated as statements under Section 161 CrPC?

Yes, applying principles from T.T. Antony and Amish Devgan, subsequent FIRs for same transaction are treated as statements under Section 161/162 CrPC. (Para 11 )

8. Does the court have power to direct clubbing of FIRs from different states?

The court can direct consolidation within a state, but cross-state transfers may be rejected; only exceptional circumstances warrant inter-state clubbing. (Para 9 )

9. What directions can be issued to police regarding future complaints related to the same transaction?

The court directed police to issue notice to the accused instead of arrest on depositor complaints, to allow ventilation of grievances. (Para 12 )

IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR BEFORE HON'BLE SHRI JUSTICE VISHAL MISHRA ON THE 9th OF OCTOBER, 2025 WRIT PETITION No. 38532 of 2025 RAVI SHANKAR TIWARI @ RAVI AND OTHERS Versus THE STATE OF MADHYA PRADESH AND OTHERS ----------------------------------------------------------------------------------

Appearance:

Shri Vishal Vincent Rajendra Daniel - Advocate for the petitioner.

Shri A.S.Baghel - V.S. Choudhary - Government Advocates for the respondents/State.

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The present petition has been filed seeking the following reliefs :-

“7.1. Issue a writ of Mandamus directing that the subsequent nine (09) FIRs i.e.:

Crime No. 649/2024 at P.S. Kotwali - Tikamgarh, Crime No.650/2024 at P.S. Kotwali - Tikamgarh, Crime No.65 1/2024 at P.S. Kotwali - Tikamgarh, Crime No.652/2024 at P.S. Kotwali - Tikamgarh, Crime No.604/2024 at P.S. Kotwali - Damoh, Crime No.570/2024 at P.S. Chanderi -Ashok Nagar, Crime No.897/2024 at P.S. Basoda - Vidisha, Crime No.067/2025 at P.S. Kotwali - Ashok Nagar and Crime No.390/2025 at P.S. Seronj - Vidisha Registered within the State of Madhya Pradesh relating to non-

payment of depositors’ maturity amounts be clubbed and proceeded with the principal FIR No. 273/2024 dated 31.07.2024 at Police Station Palera, District - Tikamgarh, M.P., by treating the said FIR as the Principal FIR, in accordance with the procedure laid down by the Hon’ble Supreme Court;

Issue an appropriate writ, order or direction that no further FIR containing similar allegations be registered in the State of Madhya Pradesh and all or raising from common cause of action, relating to non- payment of maturity proceeds be treated as statements under section 161 CrPC/180 BNSS in Crime No. 273/2024 at P.S. Palera, District — Tikamgarh, M.P., and accordingly be proceeded with, as per the guidelines set out by the Hon’ble Apex court;

Issue an appropriate writ, order or direction to the effect that in the cases where investigation officer had already filed police report Chalan under section 173 CrPC before the concerned Court and the concerned court has taken cognizance thereof, the said a FIRs and criminal cases would also stand transferred and merged/clubbed along with the principal FIR referred above and be tried by the Court having jurisdiction to try the case concerning the principal FIR, as-per the procedure established and elaborated by the Hon’ble Apex court; and Issue an appropriate writ, order or direction to the effect that if any accused has been granted bail in connection with the principal FIR or in any other FIR will stand club/merged, the bail so granted in favour of any accused, must ensure/ be applicable in all cases, which have been clubbed, in favour of such accused until the Court of competent jurisdiction cancels the same for any reason including breach of any bail condition.”

2. It is argued that with respect to same act committed by the petitioner as many as 9 FIRs have been registered against him at various places in the State of Madhya Pradesh.

3. Counsel appearing for the petitioner submits that if the trial is proceeded at different places with respect to the FIR registered against the petitioner, then the petitioner will be facing great hardships, as they are required to travel at various places to participate in a proceeding and there is a possibility of different findings recorded by the Courts and as the allegations which are made against the petitioner are one and the same in all the FIRs. There is every possibility that there may be different verdicts given by the Trial Court as they are proceeding in different trials with respect to the same incident. Placing reliance upon the judgments passed by the Hon'ble Supreme Court in the case of T.T. Antony Vs. State of Kerala reported in (2001) 6 SCC 181 as well as Abhishek Singh Chauhan Vs. Union of India and others reported in 2022 SCC Online SC 1936, Ravinder Singh Sidhu Vs. State of

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2025 Supreme(Online)(MP) 10027

IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR
Vishal Mishra, J
Ravi Shankar Tiwari @ Ravi – Appellant
Versus
State of Madhya Pradesh – Respondent
WRIT PETITION No. 38532 of 2025

Multiple FIRs registered for the same transaction or identical allegations across different jurisdictions can be clubbed with the first (principal) FIR, treating subsequent FIRs as statements to avoid multiplicity of proceedings and conflicting judicial verdicts.

Legal Category Hierarchy

Table of Contents

6. Can multiple FIRs arising from the same cause of action be clubbed together?

7. Should subsequent FIRs be treated as statements under Section 161 CrPC?

8. Does the court have power to direct clubbing of FIRs from different states?

9. What directions can be issued to police regarding future complaints related to the same transaction?

2025 Supreme(Online)(MP) 10027

IN THE HIGH COURT OF MADHYA PRADESH AT JABALPURVishal Mishra, JRavi Shankar Tiwari @ Ravi – AppellantVersusState of Madhya Pradesh – RespondentWRIT PETITION No. 38532 of 2025

Multiple FIRs registered for the same transaction or identical allegations across different jurisdictions can be clubbed with the first (principal) FIR, treating subsequent FIRs as statements to avoid multiplicity of proceedings and conflicting judicial verdicts.

Legal Category Hierarchy

Table of Contents

6. Can multiple FIRs arising from the same cause of action be clubbed together?

7. Should subsequent FIRs be treated as statements under Section 161 CrPC?

8. Does the court have power to direct clubbing of FIRs from different states?

9. What directions can be issued to police regarding future complaints related to the same transaction?

Cases Referred (3)

IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR
Vishal Mishra, J
Ravi Shankar Tiwari @ Ravi – Appellant
Versus
State of Madhya Pradesh – Respondent
WRIT PETITION No. 38532 of 2025