Legal Consolidation of Multiple FIRs: Supreme Court Ruling on Clubbing of Criminal Cases

The recent ruling by the Supreme Court in Amanat Ali vs. State of Karnataka and others addresses the consolidation of multiple FIRs registered across different states for similar offenses. This case underscores the legal principle of avoiding multiplicity of proceedings while ensuring justice is served efficiently.

Background of the Case

The petitioner, Amanat Ali, aged 60, sought the consolidation of multiple FIRs registered against him in different states. These cases were related to alleged fraud committed by a company, G. Life India Developers and Colonizers Limited, with which the petitioner claimed no direct involvement. The FIRs were registered in the states of Madhya Pradesh, Karnataka, and Jharkhand under various sections of the IPC, including Sections 406, 420, and 120B.

Petitioner’s Arguments

The petitioner argued that the cases should be consolidated to facilitate a fair and speedy trial. He contended:

The offenses were similar in nature and involved the same company.
Having cases spread across multiple states imposed an undue burden on him.
Consolidating the cases would prevent conflicting judgments and streamline the legal process.

To support his claims, he relied on previous Supreme Court rulings, including:

Satinder Singh Bhasin vs. The State of Uttar Pradesh & Anr.
Amish Devgan vs. Union of India & Ors.
Abhishek Singh Chauhan vs. Union of India & Ors.

Respondents’ Counterarguments

The respondents, representing the respective states, opposed the petition, arguing that:

The complainants and witnesses were different in each case.
Transferring cases to a single jurisdiction would cause inconvenience to witnesses.
Each FIR was based on individual causes of action and should be tried separately.

Supreme Court’s Observations

After considering the arguments, the Court noted the following:

The FIRs registered in Madhya Pradesh had a significant overlap in their nature and parties involved.
The State of Madhya Pradesh did not object to the consolidation of FIRs within its jurisdiction.
The principle of avoiding multiplicity of proceedings and ensuring judicial efficiency warranted consolidation.

Applying the precedent set in Amish Devgan v. Union of India, the Court ruled that all FIRs registered in Madhya Pradesh should be transferred to a single jurisdiction. However, the Court refused to transfer FIRs from Karnataka and Jharkhand to Madhya Pradesh, citing jurisdictional concerns and the inconvenience to local complainants.

Final Judgment

The Court ordered:

All FIRs in Madhya Pradesh to be consolidated and tried in Dewas, where the first FIR (No. 324/2017) was filed.
The respective courts to take immediate action to facilitate the transfer.
The request to transfer cases from Karnataka and Jharkhand to Madhya Pradesh was rejected.

Implications of the Ruling

This ruling reinforces the Supreme Court’s commitment to ensuring judicial efficiency while respecting jurisdictional boundaries. The judgment highlights the Court’s balancing act between facilitating a fair trial and respecting the rights of complainants and witnesses.

Petitioner Name: Amanat Ali.
Respondent Name: State of Karnataka and others.
Judgment By: Justice B.R. Gavai, Justice Aravind Kumar.
Place Of Incident: Madhya Pradesh, Karnataka, Jharkhand.
Judgment Date: 10-12-2023.

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