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Amanat Ali vs State of Karnataka and Others

Writ Petition (Criminal) · 2023 INSC 1060Decided 11 Dec 2023
Writ Petition (Criminal) No. 432 of 2022
B.R. Gavai · Aravind Kumar

Background

The petitioner, a 60-year-old man, faced six separate FIRs for financial fraud/cheating offences allegedly linked to a company, registered across Madhya Pradesh, Karnataka, and Jharkhand. He asked the Supreme Court to consolidate all six cases into a single court in Guna, Madhya Pradesh, arguing this would ensure a speedy, fair trial and avoid multiple proceedings over the same alleged scheme. The complainants and state authorities in Karnataka and Jharkhand opposed transferring their cases, since their witnesses were local and the causes of action were separate.

Decision Breakdown

The Supreme Court examined the status of each of the six FIRs and noted that four of them were already within Madhya Pradesh (Dewas, Guna, Indore, and Khargone), while the other two were in Karnataka and Jharkhand with independent complainants and investigations. Applying its power under Article 142 of the Constitution and relying on precedent (Amish Devgan v. Union of India), the Court consolidated only the four Madhya Pradesh FIRs into one trial at Dewas, since the state had no objection and multiplicity of proceedings within the same state was not in the public interest. It refused to transfer the Karnataka and Jharkhand cases, since consolidating those too would unfairly burden those complainants and witnesses without corresponding benefit.

Lesson Learnt

Courts will consolidate multiple FIRs against the same accused for a single trial where doing so serves judicial efficiency without prejudicing anyone, but consolidation is not automatic: cases with independent complainants across different states are usually left to be tried locally rather than forced into one distant court.

Official source (sci.gov.in)View Judgment (PDF)

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