Supreme Court refuses wide-ranging consolidation of multi‑state FIRs, orders limited transfers and six‑month protection with bail directions

A bench of Chief Justice B. R. Gavai and Justice K. Vinod Chandran heard writ petitions filed by partners, directors and family members of a firm seeking to club FIRs registered across several States and to bind future FIRs into one investigation. The pleas sought a single investigation and prosecution “under one roof” on the ground that multiple FIRs arose from the same cause of action.

The Court held that the prayer for clubbing FIRs across different States and for future FIRs was largely unsustainable and declined broad consolidation, while ordering limited intra‑State transfers and temporary protection for certain accused. The Court emphasised that a prayer for future FIRs "is one which cannot be granted by any court of law" and observed that consolidation by exercise of extraordinary powers had been confined to specific circumstances and with the consent of the States. The Court, in its reasoning, observed: The Court also directed that trial courts should award costs for travel and residence of prosecution witnesses if their attendance became necessary because of any transfer. On interim liberty the Court stated: "Considering the fact that they have spent months together in jail, they shall be released on bail on such conditions imposed by the Jurisdictional Magistrate, including that of cooperation in the investigation."

Background The petitions arose from complaints by investors alleging that the firm and its management diverted funds, causing loss of life‑savings. FIRs were lodged in Telangana, Karnataka, Maharashtra, West Bengal, Delhi, Andhra Pradesh and Rajasthan, and the registry tabled the nature and sections invoked, including provisions of the IT Act, state depositor protection statutes and the Telangana Protection of Depositors of Financial Establishments Act, 1999. The petitioners argued that the multiple FIRs stemmed from the same modus operandi and therefore required consolidation to avoid multiplicity and duplication of effort.

The State of Telangana resisted clubbing, stressing that offences were committed in different jurisdictions, involved distinct factual matrices and invoked diverse state enactments. The Court examined precedents including Amandeep Singh Saran, Amish Devgan, T.T. Antony and decisions where Article 142 had been invoked (Radhey Shyam; Amanat Ali) and noted the limited reach of those orders, particularly where State consent or narrow consolidation was recorded. The Court referred to Section 242 of the Bharathiya Nagarik Suraksha Sanhitha, 2023 concerning joinder of offences of the same kind within twelve months, but found that wide consolidation across States was not warranted.

Resulting orders disposed the writ petitions with limited transfers: the Madhapur, Cyberabad FIR was transferred to the Economic Offences Wing, Cyberabad; in Maharashtra, FIR No.210 (Wagle Estate, Thane) was transferred to Ambazari, Nagpur. Clubbing requests for single FIRs in Karnataka, West Bengal, Delhi, Andhra Pradesh and Rajasthan were rejected. The Court mandated that where prosecution witnesses had to travel because of transfers, the trial court should award travel and residence costs to be paid by the accused through the Court. Several petitioners who were in custody were directed to be released on bail on appropriate conditions for six months and warrants against others were stayed for six months; the petitioners were required to approach the jurisdictional courts within that period for regular bail, and cooperate with investigation, failing which investigating agencies could seek cancellation of bail. The writ petitions were disposed and pending applications were closed.

Case Details: Case No.: Writ Petition (Criminal) Dy. No.26673 of 2025 (with connected Writ Petitions Nos.269/2025, 313/2025, 319/2025, 320/2025, 321/2025) Case Title: Odela Satyam & Anr. v. The State of Telangana & Ors. Appearances: For the Petitioner(s): Advocates not indicated in the judgment For the Respondent(s): Advocates not indicated in the judgment