Allahabad High Court Upholds Multiple FIRs in Saharanpur Mob Violence Case Involving MLA Chandrashekhar

Court's Decision and Context

In a significant ruling delivered on December 17, 2025, the High Court of Judicature at Allahabad dismissed applications filed by sitting MLA Chandrashekhar Alias Ravan seeking to quash proceedings arising from four subsequent FIRs related to a violent incident on May 9, 2017, in Saharanpur, Uttar Pradesh. Justice Sameer Jain, presiding over Court No. 73, held that multiple FIRs are permissible when incidents occur at different places and times, even if part of the same broader transaction, especially if they reveal elements of a larger conspiracy. The decision rejected the alternative prayer to treat the charge-sheets as supplementary to the primary FIR (Case Crime No. 152 of 2017), emphasizing that trials are already underway in all cases.

The applications under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) stemmed from FIRs registered at Police Station Kotwali Dehat, Saharanpur, alleging mob violence by workers of the Bheem Army, led by the applicant. The court consolidated the matters for a common order, as they all arose from the same incident involving arson, property damage, and assaults on officials and civilians.

Case Overview

The central dispute revolved around a clash on May 9, 2017, where a mob of 250-300 individuals, allegedly instigated by Chandrashekhar @ Ravan and former MLA Ravindra Molhu, created disturbances, pelted stones, set vehicles and properties ablaze, and assaulted police and administrative officers in Saharanpur. The primary FIR (No. 152/2017) was lodged at 5:30 PM, detailing offenses under Sections 147, 148, 149, 307, 332, 336, 427, 436, 353, 323 of the Indian Penal Code (IPC), Section 7 of the Criminal Law Amendment Act, and Sections 3/4 of the Prevention of Damage to Public Property Act.

Subsequent FIRs followed the same day: - No. 154/2017: Lodged by journalist Sudhir Kumar Gupta for damage to his motorcycle. - No. 156/2017: Filed by Thakur Rambol Singh for arson at an under-construction Maharana Pratap building. - No. 162/2017: By Sub-Inspector Devendra Singh for assaults on police and damage to a police chauki. - No. 163/2017: By Constable Sanjeev Kumar for injuries sustained in the mob assault.

Chandrashekhar, an MLA from Nagenna Constituency, argued that all FIRs pertained to the same transaction by the same mob, rendering the subsequent ones invalid. The State opposed, highlighting distinct victims, locations, and investigative needs.

Arguments Presented

Applicant's Contentions

Represented by Senior Advocate Sushil Shukla and Nidhi, the applicant contended that the five FIRs arose from a single incident of mob agitation led by Bheem Army workers. Key points included:

- All events occurred on May 9, 2017, involving the same 250-300 agitators, common accused (including the applicant), and similar witnesses.

- Subsequent FIRs (154, 156, 162, 163/2017) were lodged after the first one, violating principles against multiple FIRs for the same transaction.

- Reliance on Supreme Court precedents like T.T. Antony vs. State of Kerala (2001) 6 SCC 181, which prohibits second FIRs for the same incident, and Babubhai vs. State of Gujarat (2010) 12 SCC 254, allowing supplementary charge-sheets instead.

- Alternatively, the charge-sheets in the subsequent cases should be merged as supplements to FIR No. 152/2017 to avoid multiplicity of proceedings.

The counsel emphasized that the first FIR encompassed arson, property damage (including police vehicles and a chauki), assaults on officials, and public disturbances, making separate FIRs impermissible.

State's Rebuttal

Additional Advocate General Manish Goyal, assisted by Roopak Chaubey, opposed quashing, arguing:

- Incidents spanned different locations (e.g., under-construction building, police chauki, journalist's vehicle) and times, with distinct victims like a private reporter and property owners.

- FIRs were lodged by different complainants, including civilians and police, with varying numbers of witnesses (e.g., 21 in FIR 152, 25 in FIR 156) and accused lists.

- Quashing would prejudice individual victims, such as the journalist whose motorcycle was burned.

- Citing State of Rajasthan vs. Surendra Singh Rathore (2025 SCC OnLine SC 358), the State asserted that multiple FIRs are allowed if ambits differ, even in the same circumstances, or if they uncover a larger conspiracy—as here, involving Bheem Army's alleged orchestrated chaos.

- Further references to Nirmal Singh Kahlon vs. State of Punjab (2009) 1 SCC 441 supported second FIRs for new discoveries or conspiracy angles.

The State stressed that no blanket rule applies; each case's facts must be evaluated independently.

Legal Precedents and Principles Applied

The court extensively analyzed Supreme Court jurisprudence on FIR multiplicity: - In T.T. Antony and Babubhai , second FIRs are barred if based on identical allegations or same transaction parts, but permissible for distinct incidents. - Nirmal Singh Kahlon permits subsequent FIRs for different versions, new factual discoveries, or larger conspiracies, especially if initial probes overlooked angles like organized unrest. - The recent Surendra Singh Rathore clarified principles, allowing second FIRs for: rival versions; differing ambits despite shared circumstances; larger conspiracies; unknown facts; or separate incidents (similar or different offenses).

Justice Jain distinguished quashing criteria: While same-transaction incidents might warrant consolidation, here differences in places, times, victims, and conspiracy elements (Bheem Army's political involvement) justified separate proceedings. The court noted trials' advanced stage—e.g., six witnesses examined in FIR 152 and 163—making quashing undesirable under inherent powers.

Pivotal excerpt: "If the ambit of two FIRs is different even though they may arise from the same set of circumstances... second FIR is permissible" ( Surendra Singh Rathore , para 9.2). Another: "The second FIR... would be maintainable... when new discovery is made on factual foundations. Discovery about a larger conspiracy can also surface" ( Nirmal Singh Kahlon , para 67).

Final Decision and Implications

The applications were dismissed, affirming the validity of all five FIRs and ongoing trials in the Special MP/MLA Courts and ADJ-12th, Saharanpur. No merger of charge-sheets was ordered, as proceedings are at the evidence stage.

This ruling reinforces flexibility in FIR registrations for mob-related violence, prioritizing victim rights and thorough investigations into potential conspiracies. For political figures like Chandrashekhar, it underscores that alleged leadership in disturbances does not entitle procedural shortcuts, potentially influencing similar cases involving communal or political clashes in Uttar Pradesh. The decision balances efficiency against justice, ensuring distinct harms (e.g., to private property) are not subsumed into a single probe.