# Ravinder Singh Sidhu v. The State of Punjab & Ors

- **Citation:** 2025 INSC 727
- **Court:** Supreme Court of India
- **Decided:** 2025-05-19
- **Bench:** B.R. Gavai, K.V. Viswanathan
- **Source:** https://unisonlegal.in/judgment/supreme-court-of-india/ravinder-singh-sidhu-v-the-state-of-punjab-ors-38377
- **Pages:** 10

## Headnote

Whether multiple FIRs registered across different States can be
clubbed and consolidated in one jurisdiction, or at least within one
district per State, under the Court's power u/Arts.32 and 142 of
the Constitution.
Headnotes†
Constitution of India - Arts.32, 142 - Clubbing and consolidation
of FIRs - Multiplicity of proceedings - Petition u/Art.32 for
clubbing and transfer of FIRs in different States - Petitioner
facing 64 FIRs in 10 States - Similar allegations arising out
of a common scheme - Writ petition seeking clubbing FIRs
within the respective States:
Held: Multiplicity of proceedings not in public interest - Since many
States have invoked local Acts, particularly the Act dealing with
the Protection of Interest of Depositors, transferring them out of
the State also will not serve the ends of justice - Correct course
of action would be to merge the FIRs with the earliest FIR in the
State concerned - If the first FIR in the respective States registered
in respect of offence under the general law and not the special
enactment, but if the subsequent FIRs now clubbed are registered
in connection with the special law or registered also in connection
with the special law, the same after clubbing must be tried under
the special law by the Special Courts - While the first FIR will be
treated as the First Information Report the subsequent FIRs in each
State shall be treated as statements u/s.161 CrPC - Investigating
Officer in the criminal case arising out of the principal FIR in the
concerned State will be free to file supplementary chargesheets after
the collation of all records concerning other FIRs in the concerned
State which are clubbed in terms of this order - If Police Report
u/s.173 CrPC stands already filed in the clubbed FIRs and the
concerned Courts have taken cognizance thereof, said FIRs and
* Author
[2025] 5 S.C.R.
2649
Ravinder Singh Sidhu v. The State of Punjab & Ors.
criminal cases would also stand transferred and merged/clubbed
along with the principal FIR to be proceeded with in accordance
with law - Supplementary charge-sheets can be filed - Bail in
principal FIR to apply to others unless distinct charges require
fresh consideration - Only one FIR each in Chhattisgarh and
Delhi, hence, not subject to clubbing - Order in exercise of powers
u/Art.32 read with Art.142 passed. [Paras 10, 19-22]

## Text

[2025] 5 S.C.R. 2648 : 2025 INSC 727
Ravinder Singh Sidhu
v.
The State of Punjab & Ors.
(Writ Petition (Criminal) No. 394 of 2024)
19 May 2025
[B.R. Gavai, CJI and K.V. Viswanathan,* J.]
Issue for Consideration
Whether multiple FIRs registered across different States can be
clubbed and consolidated in one jurisdiction, or at least within one
district per State, under the Court's power u/Arts.32 and 142 of
the Constitution.
Headnotes†
Constitution of India - Arts.32, 142 - Clubbing and consolidation
of FIRs - Multiplicity of proceedings - Petition u/Art.32 for
clubbing and transfer of FIRs in different States - Petitioner
facing 64 FIRs in 10 States - Similar allegations arising out
of a common scheme - Writ petition seeking clubbing FIRs
within the respective States:
Held: Multiplicity of proceedings not in public interest - Since many
States have invoked local Acts, particularly the Act dealing with
the Protection of Interest of Depositors, transferring them out of
the State also will not serve the ends of justice - Correct course
of action would be to merge the FIRs with the earliest FIR in the
State concerned - If the first FIR in the respective States registered
in respect of offence under the general law and not the special
enactment, but if the subsequent FIRs now clubbed are registered
in connection with the special law or registered also in connection
with the special law, the same after clubbing must be tried under
the special law by the Special Courts - While the first FIR will be
treated as the First Information Report the subsequent FIRs in each
State shall be treated as statements u/s.161 CrPC - Investigating
Officer in the criminal case arising out of the principal FIR in the
concerned State will be free to file supplementary chargesheets after
the collation of all records concerning other FIRs in the concerned
State which are clubbed in terms of this order - If Police Report
u/s.173 CrPC stands already filed in the clubbed FIRs and the
concerned Courts have taken cognizance thereof, said FIRs and
* Author
[2025] 5 S.C.R.
2649
Ravinder Singh Sidhu v. The State of Punjab & Ors.
criminal cases would also stand transferred and merged/clubbed
along with the principal FIR to be proceeded with in accordance
with law - Supplementary charge-sheets can be filed - Bail in
principal FIR to apply to others unless distinct charges require
fresh consideration - Only one FIR each in Chhattisgarh and
Delhi, hence, not subject to clubbing - Order in exercise of powers
u/Art.32 read with Art.142 passed. [Paras 10, 19-22]
Case Law Cited
Radhey Shyam v. State of Haryana, 2022 SCC OnLine SC 1935;
Abhishek Singh Chauhan v. Union of India, 2022 SCC OnLine
SC 1936 - relied on.
List of Acts
Penal Code, 1860; Code of Criminal Procedure, 1973; Prize Chits
and Money Circulation Schemes (Banning) Act, 1978; Gujarat
Police Act, 1951; Haryana Protection of Interest of Depositors in
Financial Establishment Act, 2013; Madhya Pradesh Nikshepakon
Ke Hiton Ka Sanrakshan Adhiniyam, 2000; Uttarakhand Protection
of Interests of Depositors (in Financial Establishments) Act, 2005.
List of Keywords
Clubbed FIRs; Multiplicity of proceedings; Jurisdictional
consolidation; Public interest; Criminal trial; Bail; Merging of FIRs;
Principal FIR; General law; Special law; Multiple FIRs.
Case Arising From
CRIMINAL ORIGINAL JURISDICTION: Writ Petition (Criminal)
No. 394 of 2024
Under Article 32 of The Constitution of India
Appearances for Parties
Advs. for the Petitioner:
Shyam Mehta, Sr. Adv., Mohit Paul, Ms. Rangoli Seth, Varad
Kilor, Rohit.
Advs. for the Respondents:
Amit Sharma, Ms. Manisha Aggarwal, A.A.Gs., Siddhant Sharma,
Yashraj Singh Bundela, Ms. Saloni, Arpit Garg, Dhruv Sharma,
Akshay Amritanshu, Ms. Drishti Rawal, Ms. Pragya Upadhyay, Ms.
2650
[2025] 5 S.C.R.
Supreme Court Reports
Drishti Saraf, Ms. Swati Ghildiyal, Ms. Abhipsa Mohanty, Mukesh
Kumar Maroria, Bhuvan Kapoor, Anuj Udupa, Sharath Nambiar,
Ms. Alabhaya Dhamija, Sudarshan Singh Rawat, Ms. Saakshi
Singh Rawat, Ajay Kumar Bahuguna, Saurabh Rajpal, Vinay Kumar
Singh, Arpit Bamal, Ashzad Mubarak, Ms. Nidhi Jaswal, Pradeep
Misra, Daleep Dhyani, Suraj Singh.
Judgment / Order of the Supreme Court
Judgment
K.V. Viswanathan, J.
1.
The present Writ Petition has been filed seeking to issue an
appropriate writ, order or direction for clubbing and transferring
the multiple First Information Reports (FIRs) registered against the
petitioner in different States to the Court of competent jurisdiction at
Panchkula, Haryana. Though this is the prayer made in the petition,
learned Senior Counsel for the petitioner states that he would only
press for consolidation of the multiple FIRs in each of the States to
one district within the respective States. It should also be noticed
that as far as the original prayer made in the petition is concerned,
on facts, it was clearly not maintainable since a similar prayer made
by the petitioner in Writ Petition (Criminal) No. 206 of 2020 filed in
this Court on 20.07.2020 was rejected on 17.08.2020. Considering
the fact that the petitioner is now seeking the alternative prayer and
the respective States during the hearing have not objected to the
same, we have decided to entertain the petition in the special facts
and circumstances of the case.
2.
In all, there are 64 FIRs registered in 10 States. The States
concerned which are parties to the writ petition are Punjab (23
FIRs), Madhya Pradesh (2 FIRs), Haryana (6 FIRs), Gujarat (4
FIRs), Chhattisgarh (1 FIR), NCT of Delhi (1 FIR), Uttarakhand (5
FIRs), Rajasthan (5 FIRs), Uttar Pradesh (15 FIRs) and Himachal
Pradesh (2 FIRs).
3.
It should also be mentioned that, out of the above, already trial is
concluded in some and in three cases convictions have been recorded.
In two cases acquittals have been recorded, in two cases there have
been cancellation reports, 15 cases are at the evidence stage and 21
[2025] 5 S.C.R.
2651
Ravinder Singh Sidhu v. The State of Punjab & Ors.
cases are at the stage where charge-sheets have been filed. We are
not concerned with the cases where convictions or acquittals have
been recorded or in some cases where cancellation reports are filed.
4.
The different FIRs are primarily for offences under Sections 406,
420, 465, 467, 468, 471 read with Section 120B, 34, 263, 114 of the
Indian Penal Code, 1860 (IPC). Some of the Sections referred to
herein have been invoked in a few FIRs and in some all the Sections
have been invoked. Along with this in some FIRs the local Acts of
the State like the Gujarat Police Act, 1951, the Haryana Protection
of Interest of Depositors in Financial Establishment Act, 2013, the
Prize Chits And Money Circulation Schemes (Banning) Act, 1978, the
Madhya Pradesh Nikshepakon Ke Hiton Ka Sanrakshan Adhiniyam,
2000 and the Uttarakhand Protection of Interests of Depositors (in
Financial Establishments) Act, 2005 have been invoked depending
upon the State concerned.
5.
The petitioner herein Ravinder Singh Sidhu has been in custody since
11.10.2018. He was the Managing Director of KIM Infrastructure and
Developers Limited (for short 'KIDL'). The petitioner along with other
directors is alleged to have floated two schemes for allotment of
developed land where customers were lured to be part of a lumpsum
payment plan or a deferred payment plan.
6.
When the matters stood thus, Writ Petition No. 3332 of 2010 was
filed before the High Court of Madhya Pradesh at its Gwalior Bench
for inquiry against financial companies including 'KIDL', on the ground
that the companies were seeking deposits from the public with
promise of repayment with higher returns ranging from 15 to 20 per
cent. The High Court ordered an inquiry by the Central Bureau of
Investigation (CBI). The CBI conducted a preliminary investigation
and submitted a report concluding that many of the named companies
indulged in profiteering schemes without even having the capacity
to repay along with the promised rate of return.
7.
On 13.07.2012, the Writ Petition was disposed of by the High Court
with a direction to the concerned authorities to take appropriate action
in accordance with law. Pursuant thereto, the Securities and Exchange
Board of India (SEBI) initiated inquiry against 'KIDL'. KIDL's attempt
to get the scheme registered as a Collective Investment Scheme
(CIS) was rejected on the ground that possessing a registration
was a pre-condition for initiating/launching/sponsoring (CIS) under
2652
[2025] 5 S.C.R.
Supreme Court Reports
the SEBI Act, 1992. Certain proceedings were taken by SEBI with
which we are not directly concerned here.
8.
In the meantime, the first FIR came to be registered against KIDL
and its directors by investors as well as by agents appointed by KIDL
for mobilizing the investment money. As stated earlier, multiple FIRs
came to be registered alleging commission of diverse offences due
to default in honoring the commitments and due to failure of KIDL
and the petitioner to repay the amounts. It is in this background that
the present Writ Petition came to be filed.
9.
Notices were issued in the Writ Petition and the States of
Uttarakhand, Punjab, Madhya Pradesh, Rajasthan, Gujarat and
Uttar Pradesh have filed counter affidavits. Though in the counter
affidavits, the States have opposed the clubbing, at the hearing
there was a broad consensus about consolidating the cases in the
respective States.
10. Heard learned Senior Counsel/Counsel for the parties. The law in
this issue is now fairly well settled. It has been held by this Court
that multiplicity of proceedings will not be in larger public interest.
Further, since many States have invoked local Acts, particularly the
Act dealing with the Protection of Interest of Depositors, transferring
them out of the State also will not serve the ends of justice. Hence,
the correct course of action would be to merge the FIRs with the
earliest FIR in the State concerned. It is clarified that if the first FIR
in the respective States of Gujarat, Haryana, Himachal Pradesh,
Madhya Pradesh, Punjab, Rajasthan, Uttar Pradesh and Uttarakhand
is registered in respect of offence under the general law and not
the special enactment, but if the subsequent FIRs now clubbed are
registered in connection with the special law or registered also in
connection with the special law, the same after clubbing must be
tried under the special law by the Special Court(s). [See Radhey
Shyam v. State of Haryana and Ors., 2022 SCC OnLine SC 1935
and Abhishek Singh Chauhan v. Union of India and Ors., 2022
SCC OnLine SC 1936].
11. We propose to follow the said course of action. In view of the above
in the State of Gujarat, the following 3 FIRs will now be merged
with FIR No. I-79/2018 dated 27.09.2018 registered at Bhavnagar
Gangajaliya.
[2025] 5 S.C.R.
2653
Ravinder Singh Sidhu v. The State of Punjab & Ors.
Sr.
No.
FIR No.
Date
Police
Station
Place
1.
I-92/2018
26.11.2018
Bhavnagar
Gangajaliya
2.
I-293/2018
18.11.2018
P.S. Vadaj
Ahmedabad City
3.
I-285/2018
14.11.2018
P.S. Vadaj
Ahmedabad City
12. In the State of Haryana, the following 5 FIRs will now be merged
with FIR No. 24/2018 dated 16.01.2018 registered at Ambala P.S.
Ambala Cant.
Sr.
No.
FIR No.
Date
Police Station
Place
1.
98/2019
04.04.2019
Bhiwani Civil
Lines
Bhiwani
2.
167/2022
01.08.2022
Raipur Rani
Panchkula
3.
235/2021
21.05.2021
Hisar City
Hisar
4.
1015/2018
09.10.2018
Sirsa City
Sirsa
5.
503/2019
COMI No.
110/2020)
NA
Narnaul
Narnaul
13. In the State of Himachal Pradesh, the following FIR will now be
merged with FIR No. 13/2019 registered at Hamirpur, P.S. Sujanpur
Tira.
Sr.
No.
FIR No.
Date
Police Station
Place
1.
202/2019
09.12.2019
Jawali
Kangra
14. In the State of Madhya Pradesh, the following FIR will now be
merged with FIR No. 496/2018 dated 05.12.2018 registered at
Jabalpur P.S. Lordganj.
2654
[2025] 5 S.C.R.
Supreme Court Reports
Sr.
No.
FIR No.
Date
Police Station
Place
1.
176/2020
24.05.2020
Kotwali Anuppur
Anuppur
15. In the State of Punjab, the following 16 FIRs will now be merged
with FIR No. 198/2018 dated 23.10.2018 registered at SAS Nagar,
P.S. Phase I.
Sr.
No.
FIR No.
Date
Police Station
Place
1.
183/2020
12.08.2020
Dasuya
Hoshiarpur
2.
62/2021
21.04.2021
Dasuya
Hoshiarpur
3.
291/2020
16.12.2020
Dasuya
Hoshiarpur
4.
81/2021
21.04.2021
City Gurdaspur
Gurdaspur
5.
151/2021
04.08.2021
City Hoshiarpur
Hoshiarpur
6.
280/2020
12.12.2020
City Hoshiarpur
Hoshiarpur
7.
30/2022
04.03.2022
Anaj Mandi
Patiala
8.
55/2021
23.05.2021
Talwara
Hoshiarpur
9.
99/2021
20.05.2021
Talwara
Hoshiarpur
10.
64/2021
20.05.2021
City Batala
Batala
(Gurdaspur)
11.
141/2019
02.09.2019
City Gurdaspur
Gurdaspur
P.S.
12.
0043/2019
12.02.2019
City Tarn Taran
Tarn Taran
13.
07/2021
16.01.2021
City
Hoshiarpur
14.
53/2021
29.03.2021
City
Hoshiarpur
15.
05/2024
06.03.2024
N.R.I.
Amritsar
16.
144/2024
29.10.2024
Kotwali
Bathinda
[2025] 5 S.C.R.
2655
Ravinder Singh Sidhu v. The State of Punjab & Ors.
16. In the State of Rajasthan, the following 3 FIRs will now be merged
with FIR No. 878/2018 dated 20.11.2018 registered at Karauli P.S.
Hindon.
Sr.
No.
FIR No.
Date
Police Station
Place
1.
125/2019
06.06.2019
Tibbi
Hanumangarh
2.
90/2019
12.03.2019
Bhupalpura
Udaipur
3.
292/2019
05.08.2019
Vidhayakpuri
Jaipur City
(South)
17. In the State of Uttar Pradesh, the following 14 FIRs will now be
merged with FIR No. 28/2019 dated 13.01.2019 registered at Basti
P.S. Kotwali.
Sr.
No.
FIR No.
Date
Police
Station
Place
1.
82/2019
09.02.2019
Hari Parvat
Agra
2.
303/2019
25.06.2019
Aonla
Bareilly
3.
617/2020
25.12.2020
Nawabad
Jhansi
4.
33/2019
15.03.2019
Harbans
Mohal
East (Commissionerate
Kanpur City)
5.
55/2019
11.05.2019
Harbans
Mohal
East (Commissionerate
Kanpur City)
6.
57/2019
14.05.2019
Harbans
Mohal
East (Commissionerate
Kanpur City)
7.
480/2020
Sungarhi
Pilibhit
8.
409/2019
Sungarhi
Pilibhit
9.
119/2019
15.02.2019
Sigra
Kashi
(Commissionerate
Varanasi)
10.
189/2019
29.05.2019
Bhadohi
Bhadohi
11.
406/2019
19.05.2019
Cantt
Gorakhpur
12.
361/2019
18.06.2019
Sigra
Varanasi
13.
463/2019
23.10.2019
Sigra
Varanasi
14.
280/2022
Bareilly
Faridpur
2656
[2025] 5 S.C.R.
Supreme Court Reports
18. In the State of Uttarakhand, the following 4 FIRs will now be merged
with FIR No. 107/2018 dated 30.10.2018 registered at Pithoragarh
P.S. Kotwali Pithoragarh.
Sr.
No.
FIR No.
Date
Police Station
Place
1.
165/2019
24.08.2019
Mukhani
Nainital
2.
30/2019
07.07.2019
Lohaghat
Champawat
3.
44/2019
19.02.2019
Jaspur
Udham Singh
Nagar
4.
86/2024
24.04.2024
Mukhani
Nainital
19. The writ petition stands allowed in the above terms. We further
direct while the first FIR will be treated as the First Information
Report (hereinafter for convenience called the 'principal FIR'), the
subsequent FIRs in each State shall be treated as Statements under
Section 161 of the Code of Criminal Procedure, 1973 (CrPC). The
Investigating Officer in the criminal case arising out of the principal
FIR in the concerned State will be free to file supplementary chargesheets after the collation of all records concerning other FIRs in
the concerned State which are clubbed in terms of this order. We
further direct that if Police Report under Section 173 of CrPC stands
already filed in the clubbed FIRs and the concerned Courts have
taken cognizance thereof, the said FIRs and criminal cases would
also stand transferred and merged/clubbed along with the principal
FIR to be proceeded with in accordance with law.
20. The investigating officer in the principal proceedings will be free to
file supplementary charge-sheet on the basis of the material collated
during investigation of other FIRs. We also make it clear that the
other offences not part of the special enactments can also be tried
by the Special Court under the concerned State legislation. We
also further direct that in case the petitioner has been granted bail
in connection with the principal proceeding/criminal case to which
the other cases have been clubbed, the bail so granted must enure
to the petitioner's favour in the other FIRs now clubbed as well. We
further clarify that if the principal FIR is limited to offence under the
general law/Penal Code but the subsequent FIRs contain allegations
[2025] 5 S.C.R.
2657
Ravinder Singh Sidhu v. The State of Punjab & Ors.
attracting offences under the special enactment or certain other IPC
offences and if the bail granted is only for some offences under the
general law, the Special Court is entitled to insist for a fresh bail
application to be filed by the petitioner in relation to those offences
including under the Special Act. The said bail application(s) shall be
decided on its own merits in accordance with law.
21. We make it clear that our direction is confined to the offences
mentioned in the present order, namely, the offences under the IPC
and the concerned State enactment mentioned herein.
22. As far as the State of Chhattisgarh and NCT of Delhi are concerned,
since there is only one case each, the said case will proceed in
those States in accordance with law and the question of clubbing
does not arise. We have passed the above order in exercise of
powers under Article 32 read with our powers under Article 142 of
the Constitution of India.
Result of the case: Writ Petition allowed.
†Headnotes prepared by: Aishani Narain, Hony. Associate Editor
(Verified by: Nidhi Jain, Editor)