The Supreme Court exercised powers under Article 142 of the Constitution to consolidate 64 FIRs across 10 states into single trials per state, merging subsequent FIRs with the earliest FIR in each jurisdiction. Subsequent FIRs were deemed Section 161 CrPC statements, enabling supplementary chargesheets under Section 173 CrPC. Bail in the principal FIR applies to clubbed cases, except where special enactments require fresh bail applications. Special Courts may try all offences, including IPC violations, under state laws. Single-FIR states proceed independently.
Facts Of The Case:
Ravinder Singh Sidhu, Managing Director of KIM Infrastructure and Developers Limited (KIDL), has been in custody since 11 October 2018. He faces 64 FIRs across 10 states (Punjab-23, Uttar Pradesh-15, Haryana-6, Uttarakhand-5, Rajasthan-5, Gujarat-4, Madhya Pradesh-2, Himachal Pradesh-2, Chhattisgarh-1, Delhi-1) filed by investors and agents. The allegations stem from KIDL’s land allotment schemes (lumpsum/deferred payment plans), where investors were promised high returns but KIDL defaulted on repayments. FIRs invoke Sections 406, 420, 465, 467, 468, 471/120B/34 IPC and state-specific laws (e.g., Haryana/Uttarakhand Depositors Protection Acts). Three cases resulted in conviction, two in acquittal, two were cancelled, 15 are at the evidence stage, and 21 have chargesheets filed. The litigation originated from a 2010 Madhya Pradesh High Court order (WP No. 3332/2010) directing a CBI probe into KIDL’s operations, later investigated by SEBI, which rejected KIDL’s investment scheme registration. Sidhu sought consolidation of all FIRs to one district per state under Article 32. States initially opposed clubbing but consented during hearings.
Procedural History:
The petitioner filed Writ Petition (Crl.) No. 394/2024 under Article 32 seeking clubbing/transfer of 64 FIRs across 10 states to Panchkula, Haryana. This followed an earlier rejected plea (WP(Crl.) No. 206/2020, dismissed on 17.08.2020). During proceedings, the petitioner amended his prayer to seek state-wise consolidation instead of nationwide transfer. The Supreme Court issued notices to all respondent states. Six states (Uttarakhand, Punjab, Madhya Pradesh, Rajasthan, Gujarat, Uttar Pradesh) filed counter-affidavits initially opposing clubbing. At the hearing, all states consented to consolidating FIRs within their respective jurisdictions. The Court invoked Article 142 to merge subsequent FIRs with the earliest FIR in each state, referencing precedents (Radhey Shyam, 2022; Abhishek Singh Chauhan, 2022). Detailed merger directives were issued for 8 states (excluding Chhattisgarh/Delhi with single FIRs), specifying treatment of chargesheets, bail continuity, and trial procedures under special/general laws.
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Court Observation:
The Court observed that multiplicity of FIRs across states violates the interests of justice and public policy, necessitating consolidation within each state to avoid fragmented trials. It held that transferring cases involving state-specific special enactments (e.g., depositor protection laws) outside the originating state would undermine their enforcement. Subsequent FIRs were deemed supplementary statements under Section 161 CrPC, requiring merger with the earliest (“principal”) FIR in each state. The Court clarified that Special Courts may try all offences—including IPC violations—under state laws, and bail granted in the principal FIR extends to clubbed cases, except where special enactments necessitate fresh bail applications. This directive was issued under Article 142 to ensure cohesive trials.
Final Decision & Judgement:
The Supreme Court allowed the writ petition under Article 142, directing state-wise consolidation of 64 FIRs across 10 states. All FIRs in Gujarat, Haryana, Himachal Pradesh, Madhya Pradesh, Punjab, Rajasthan, Uttar Pradesh, and Uttarakhand were merged with the earliest (“principal”) FIR in each state. Subsequent FIRs were deemed supplementary statements under Section 161 CrPC. Investigating officers may file supplementary chargesheets under Section 173 CrPC after evidence collation. Bail granted in the principal FIR applies to all clubbed cases, except where offences under state-specific special enactments require fresh bail applications. Special Courts may try all offences, including IPC violations. Chhattisgarh and Delhi (single FIRs each) proceed independently. Trials must comply with state laws where depositor protection statutes apply.
Case Details:
Case Title:Ravinder Singh Sidhu vs. The State of Punjab & Ors. Citation:2025 INSC 727 Appeal No.:Writ Petition (Crl.) No. 394 of 2024 Date of Judgment:May 19, 2025 Judges/Justices: Chief Justice B.R. Gavai & Justice K.V. Viswanathan
Download The Judgement Here