Allahabad High Court Rejects Quashing of Multiple FIRs in Saharanpur Riot Case Involving MLA Chandrashekhar

Court Upholds Separate Proceedings for Distinct Incidents

The High Court of Judicature at Allahabad, in a judgment delivered on December 17, 2025, by Hon'ble Justice Sameer Jain, dismissed applications filed by sitting MLA Chandrashekhar Alias Ravan seeking to quash charge-sheets and proceedings arising from four subsequent FIRs related to a violent incident on May 9, 2017, in Saharanpur, Uttar Pradesh. The court ruled that while the incidents may form part of the same transaction, their distinct nature, different locations, and potential involvement of a larger conspiracy justify maintaining separate FIRs and trials.

The applications, numbered 39425/2025, 39419/2025, and others, stemmed from FIR No. 152/2017 (the primary FIR) and subsequent FIRs Nos. 154, 156, 162, and 163/2017, all registered at Police Station Kotwali Dehat, Saharanpur. The applicant, represented by Senior Advocate Sushil Shukla and Nidhi, argued for quashing the later proceedings or treating their charge-sheets as supplements to the first FIR.

Background of the Case

The cases arise from alleged violent clashes on May 9, 2017, involving a mob of 250-300 persons, purportedly led by Chandrashekhar Alias Ravan and associates from the Bheem Army. The primary FIR (No. 152/2017), lodged at 17:30 hours, accused the group of rioting (Sections 147, 148, 149 IPC), attempt to murder (Section 307 IPC), endangering life (Section 336 IPC), mischief by fire (Sections 435, 436 IPC), assault on public servants (Sections 332, 353 IPC), and causing hurt (Section 323 IPC), along with violations under Section 7 of the Criminal Law Amendment Act and Sections 3/4 of the Prevention of Damage to Public Property Act.

Subsequent FIRs detailed specific damages and assaults: - FIR No. 154/2017: Lodged by journalist Sudhir Kumar Gupta for the burning of his motorcycle during stone-pelting. - FIR No. 156/2017: Filed by Thakur Rambol Singh regarding arson at an under-construction Maharana Pratap building, including firing by the applicant. - FIR No. 162/2017: By Sub-Inspector Devendra Singh, alleging assault on police and damage to a police post and vehicles. - FIR No. 163/2017: By Constable Sanjeev Kumar, reporting injuries from mob assault on officials.

All FIRs were registered on the same day, naming the applicant among 19-70 known accused and unknown persons. Trials in these cases, pending before the Special MP/MLA Court and ADJ-12th Saharanpur, are at the evidence stage, with witnesses already examined in each.

Arguments Presented

Applicant's Contentions:
The defense argued that all FIRs pertain to the same mob-led incident occurring in a single transaction, rendering subsequent FIRs impermissible under precedents like T.T. Antony v. State of Kerala (2001) 6 SCC 181 and Babubhai v. State of Gujarat (2010) 12 SCC 254. They claimed common accused, witnesses, and allegations of arson, property damage, and assaults on officials, urging quashing or consolidation as supplementary charge-sheets to avoid multiplicity. Reliance was also placed on Amitbhai Anilchandra Shah v. CBI (2013) 6 SCC 348, emphasizing that separate FIRs for the same transaction are invalid.

State's Rebuttal:
Additional Advocate General Manish Goyal, assisted by Roopak Chaubey, countered that the FIRs describe distinct incidents at different times and places, lodged by varied complainants (e.g., a journalist, a builder, police officials). They highlighted differing witness lists (21-29 per case) and non-common victims, arguing that quashing would prejudice individuals. Citing State of Rajasthan v. Surendra Singh Rathore (2025 SCC OnLine SC 358), the State asserted that separate FIRs are allowable if ambits differ, even in the same circumstances, or if they reveal a larger conspiracy—as suggested by the Bheem Army's coordinated chaos. Nirmal Singh Kahlon v. State of Punjab (2009) 1 SCC 441 was invoked to support subsequent FIRs for new discoveries or conspiracies.

Key Legal Precedents and Principles Applied

The court meticulously analyzed Supreme Court rulings to delineate when multiple FIRs are barred. In T.T. Antony and Babubhai , second FIRs are impermissible for the same incident or transaction to prevent harassment. However, distinctions were drawn: Babubhai permits separate FIRs for "two different incidents/crimes," while Nirmal Singh Kahlon allows them for differing versions, new factual discoveries, or larger conspiracies overlooked initially.

Justice Jain emphasized Surendra Singh Rathore 's recent principles (paragraph 9), permitting second FIRs when: - Ambits differ despite shared circumstances. - They uncover larger conspiracies or unknown facts. - Incidents are separate, even if offenses overlap.

The court noted the mob's actions spanned hours across locations, fitting a conspiracy narrative involving political elements, thus warranting separate probes.

Pivotal excerpt from the judgment:
"From perusal of all the FIRs... it reflects, place and time of the incident of all the FIRs are different... it cannot be said these FIRs are relating to same incident... if second FIR is in respect of two different incident/crime, the second FIR is permissible."

Another key observation:
"[I]t appears to be a case in which... all the incidents relate to same transaction but considering the fact that applicant is sitting M.L.A. relating to political party and alleged offences were allegedly committed by his party workers, the arguments... that it appears to be a case which involves larger conspiracy cannot be ruled out."

Court's Decision and Implications

The applications were dismissed, affirming the validity of all FIRs and ongoing trials. The court declined to quash proceedings or merge charge-sheets, citing advanced trial stages (e.g., 6 witnesses examined in FIR No. 152/2017) and the undesirability of invoking inherent powers mid-trial.

This ruling reinforces flexibility in FIR registrations for multi-faceted incidents, particularly those hinting at organized unrest, balancing victim rights against accused protections. It may guide lower courts in handling riot or protest-related cases with multiple complainants, potentially influencing similar politically charged matters in Uttar Pradesh. No immediate appeal details were mentioned, but the decision underscores the judiciary's caution against procedural multiplicity without clear overlap.