Consolidation of trials for multiple offenses of the same kind committed within twelve months is permissible under Section 242 of the Bharatiya Nagarik Suraksha Sanhita, 2023, but such a request is premature if the cases are at different stages of investigation and trial.

ORDER:

This Writ Petition is filed with the following relief:

“…to issue any appropriate writ. order or direction one more particularly one in the nature of Writ of Mandamus declaring the action of the Respondents in registering Multiple FIR in respect of the same offence against the accused on similar facts and same set of allegations arising out of transaction already covered in the Crime. No.3 OF 2020, dated 02-01-2020 on the file of the Honble IX Addl Metropolitan Magistrate, At Kukatpally,Cyberabad as illegal, arbitrary and unconstitutional and consequently direct the Respondents to club the Crime No.331 of 2020 pending on the file of the Honble XII Additional Chief Metropolitan Magistrate, At, Hyderabad and Crime No. 255 of 2020 pending on the tile of the Honble IX Addl Metropolitan Magistrate, At Kukatpally,Cyberabad along with Crime No.331of 2020 pending Honorable IX Addl Metropolitan Magistrate, At Kukatpally,Cyberabad and make over the investigation of all cases relating to the petitioners relating to the 4th respondent and pass............”

Heard Mr.Naresh Reddy Chinnolla, learned counsel for the petitioners and Mr.D.Pradeep, learned Assistant Government Pleader for Home.

Learned counsel for the petitioner submits that the registration of multiple crimes in respect of the same or similar set of allegations against the petitioner is impermissible in law and contrary to settled legal principles. It is contended that Crime Nos. 03 of 2020, 255 of 2020, and 331 of 2020 have been registered against the petitioner on similar allegations relating to the misuse of a credit card belonging to a deceased person. Placing reliance on the judgment of the Hon’ble Supreme Court in Odela Satyam and another v. State of Telangana and others , 2025 INSC 1174, learned counsel submits that where multiple offences of the same kind are committed within a period of one year, they may be tried together in a single trial. On the strength of the said legal position, a direction is sought from this Court for appropriate consolidation or unified trial.

Learned Assistant Government Pleader for Home, on the other hand, submits that, during the pendency of the present writ petition, investigation in the three crimes has progressed. It is submitted that in Crime No. 331 of 2020, a final report was filed on 27.02.2021 before the learned XIII Additional Judicial Magistrate of First Class, Kukatpally, endorsing the case as “undetected.” In respect of Crime No. 03 of 2020, a charge sheet has been filed and the matter is presently pending before the competent Court for numbering as a calendar case. Insofar as Crime No. 255 of 2020 is concerned, the same is still under investigation. It is therefore contended that, as on date, only one case has progressed to the stage of trial (subject to cognizance by the Magistrate), and hence, the relief sought by the petitioner at this stage is premature. Accordingly, appropriate orders are sought.

I have perused the material available on record.

The grievance of the petitioner is that, in respect of similar allegations arising out of the same or connected transactions, multiple crimes have been registered and that such matters ought to be tried in a consolidated manner by a single trial Court. However, the factual position, as explained by the learned Assistant Government Pleader, indicates that out of the three crimes, one has already been closed by filing a final report, another has culminated in filing of a charge sheet, and the third remains under investigation. Therefore, as on date, only one case is at a stage where trial proceedings may commence, subject to cognizance by the Magistrate.

At this juncture, it would be premature to presume that the pending investigation in Crime No. 255 of 2020 would necessarily result in filing of a charge sheet so as to warrant consolidation of trials. The possibility of the investigation resulting in closure cannot be ruled out. Hence, any direction