Apex Court consolidates FIRs in 'Brahma City' project case to prevent multiplicity and ensure comprehensive investigation.
In a significant ruling, the Supreme Court of India has directed the consolidation of multiple First Information Reports (FIRs) filed against M/s Krrish Realtech Pvt. Ltd., related to the real estate project "Brahma City/Krrish World". The judgment aims to streamline the investigation process and prevent prejudice against the accused by allowing a single, comprehensive investigation into the allegations.
The case, titled "Amit Katyal v. State of Haryana," revolved around multiple FIRs lodged in Delhi and Haryana. The FIRs were based on similar allegations against the company and its directors, including non-delivery of plots, misappropriation of funds, and cheating the homebuyers. The primary FIRs in question were FIR No. 30/2019 registered with the Economic Offences Wing, Delhi, and FIR No. 439/2024 at PS Sector-65, Gurugram, Haryana.
The bench, comprising Justices Pankaj Mithal and Prasanna B. Varale, relied on the precedent set in the case of "T.T. Antony v. State of Kerala," which prohibits multiple FIRs for the same occurrence or transaction. The court emphasized that allowing parallel investigations would lead to conflicting findings and serious prejudice against the accused.
In its judgment dated May 18, 2026, the court directed that FIR No. 30/2019 be transferred and clubbed with FIR No. 439/2024 in Haryana for a unified investigation. This decision, the court noted, would ensure a coordinated and effective investigation while safeguarding the rights of the accused to defend themselves adequately.
However, the court declined the petitioners' request for blanket protection against future FIRs, stating that such directions would be inappropriate. It clarified that the petitioners could seek legal remedies if any new FIRs are registered based on the same transaction.
The judgment is expected to have significant implications for the handling of similar cases, reinforcing the principle of preventing multiplicity of proceedings and ensuring justice through a singular investigative process.
Bottom Line:
FIRs arising out of the same set of facts or transactions cannot be registered in multiple jurisdictions. The principle laid down in T.T. Antony v. State of Kerala prohibits multiple FIRs for the same occurrence or transaction, ensuring a single, comprehensive investigation with supplementary reports, if necessary.
Statutory provision(s): Criminal Procedure Code, 1973 - Sections 154, 173, 156, 157, 162, 482
Amit Katyal v. State of Haryana, (SC) : Law Finder Doc id # 2901877
