Amit Katyal v. State of Haryana
Supreme Court of India2026 INSC 509Bench: Justice Pankaj Mithal and Justice Prasanna B. Varale
The Supreme Court reaffirmed the cardinal principle that there cannot be multiple First Information Reports in respect of the same occurrence or the same transaction giving rise to one or more cognizable offences, and applied that principle to direct the clubbing of several FIRs filed against the Directors of a real-estate company across different police stations in respect of the same project. The Bench reiterated the test laid down in T.T. Antony v. State of Kerala (2001) and elaborated in Babubhai v. State of Gujarat (2010) — namely, whether the second FIR pertains to the same incident or transaction, or whether it discloses a distinct offence with a separate cause of action. Where multiple FIRs concern essentially the same transaction, even if lodged by different complainants and registered at different police stations, the registration and continuation of all of them simultaneously would amount to harassment of the accused, would offend the rule against double jeopardy in spirit if not in strict Article 20(2) terms, and would militate against the fair-investigation guarantee that is part of Article 21. The Court invoked its extraordinary jurisdiction under Article 32 to direct that the multiple FIRs lodged in respect of the 'Brahma City' / 'Krrish World' real-estate project in Gurugram be consolidated and investigated together by a designated investigating agency, so as to obviate multiplicity of proceedings and the attendant abuse of process.