High Court of Bombay Allows Clubbing of Multiple FIRs Against Accused in Economic Offences. The court determined that the FIRs contained similar allegations and should be tried together to ensure efficient administration of justice.

High Court: Bombay High Court Bench: BOMBAY In Favour of Accused
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Case Note & Summary

The petitioner, Vishnu Ramchandra Bhagwat, sought the clubbing of ten FIRs registered against him under various sections of the Indian Penal Code, 1860, the Maharashtra Protection of Interest of Depositors (in Financial Establishments) Act, 1999, and the Prize Chits and Money Circulation Schemes (Banning) Act, 1978. The FIRs were filed by various police stations in Maharashtra, alleging that the petitioner, as the Director and Promoter of three cooperative societies, accepted deposits from complainants with promises of high returns but failed to repay them. The petitioner argued that the complaints arose from a campaign of misinformation by a self-proclaimed RTI activist, Ganesh Kankal, who had attempted to extort money from him. The petitioner contended that the FIRs were based on identical allegations and that he had been granted bail in each case. The court noted that the allegations in all FIRs were substantially the same and that clubbing them would facilitate efficient justice. Citing several Supreme Court judgments, the court held that the FIRs should be tried together to avoid multiplicity of proceedings. The court directed the transfer of all cases to the court handling the first FIR and allowed the petitioner to bear the expenses for witnesses' travel and accommodation. The judgment was pronounced on October 22, 2026, and the court ordered the transfer process to be completed within 30 days.

Headnote

A) Criminal Procedure - Clubbing of FIRs - Transfer of multiple FIRs for common trial - Code of Criminal Procedure, 1973, Section 161 - The court allowed the clubbing of ten FIRs against the petitioner as they contained substantially similar allegations regarding non-repayment of deposits. The decision was based on the principle of efficient administration of justice and the need to avoid multiplicity of proceedings, following precedents set by the Supreme Court. Held that all FIRs should be tried together in one court (Paras 6-12).

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Issue of Consideration

Whether multiple FIRs against the petitioner can be clubbed for a single trial due to identical allegations.

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Final Decision

The court allowed the petition for clubbing the ten FIRs, directing that they be tried together in one court due to the identical nature of allegations. The court ordered the transfer of cases to the court handling the first FIR and directed that the process be completed within 30 days.

Law Points

  • Clubbing of FIRs
  • Efficient administration of justice
  • Article 142 of the Constitution
  • Similar allegations in FIRs
  • Transfer of cases to a single court
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Case Details

2026 LawText (BOM) (10) 59

TSB J-WP-1585-2023

2026-10-22

Kamal Khata, A.S. Gadkari

Mr. Vikram Parmar, Mr. Ajay S. Patil

Vishnu Ramchandra Bhagwat

State of Maharashtra

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Nature of Litigation

Petition for clubbing multiple FIRs

Remedy Sought

Petitioner sought clubbing of ten FIRs for a single trial

Filing Reason

Allegations of non-repayment of deposits

Previous Decisions

Petitioner granted bail in each FIR

Issues

Whether multiple FIRs can be clubbed for a single trial Whether the allegations in the FIRs are substantially similar

Submissions/Arguments

Petitioner argued that FIRs were based on identical allegations and clubbing was necessary for justice. Respondent argued against the clubbing of FIRs.

Ratio Decidendi

The court emphasized the need for efficient administration of justice and the avoidance of multiplicity of proceedings, allowing for the clubbing of FIRs with similar allegations.

Judgment Excerpts

The law on clubbing of FIRs and transferring them to a Special Court for a common trial in offences registered under a similar scheme is now well settled. In our view, clubbing of FIRs would facilitate the efficient administration of justice to expedite the trial of all the cases mentioned above. We direct Registrar (Judicial-I) to forward a copy of this judgment to all the Courts where charge-sheets have been filed.

Procedural History

The petition was filed seeking the clubbing of ten FIRs. The court heard the petition and the arguments from both sides before making its decision.

Acts & Sections

  • Indian Penal Code, 1860: 406, 409, 420, 467, 468, 201, 120B, 34
  • Maharashtra Protection of Interest of Depositors (in Financial Establishments) Act, 1999: 3, 4
  • Prize Chits and Money Circulation Schemes (Banning) Act, 1978: 4, 5, 6
  • Arms Act, 1959: 25(3)
  • Code of Criminal Procedure, 1973: 161
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