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Amit Katyal & Anr. v. State of Haryana & Anr.

Writ Petition (Criminal) · 2026 INSC 509Decided 18 May 2026
W.P.(Crl.) No.-000067-000067 - 2025
Justice Pankaj Mithal · Justice Prasanna B. Varale · Justice Aravind Kumar

Background

The petitioners were directors of a real estate company whose flagship project got delayed, leading unpaid homebuyers to file multiple FIRs against them in different cities: several with the Economic Offences Wing in Delhi and others in Haryana, all arising from essentially the same set of transactions. The petitioners approached the Supreme Court directly under Article 32, asking that all these FIRs be clubbed together and that no coercive action be taken on any future FIRs, arguing that facing parallel investigations in different states over the same facts was unfair and prejudicial.

Decision Breakdown

The Court applied the settled principle from T.T. Antony v. State of Kerala that there cannot be multiple FIRs for the same occurrence or transaction. The law contemplates one comprehensive investigation with room for further investigation and supplementary reports, not parallel investigations in different jurisdictions. Finding that a Haryana FIR (No. 439/2024) arose from the same allegations already under investigation in a Delhi EOW FIR (No. 30/2019), the Court ordered the Delhi FIR to be transferred and clubbed with the Haryana FIR for a single, coordinated investigation. However, it declined the broader request for a blanket protection against any future FIRs, holding that would not be an appropriate or permissible direction to give in advance, while clarifying the petitioners remain free to seek legal remedies if any such future FIR is actually registered.

Lesson Learnt

When multiple FIRs are lodged in different places over the same underlying transaction, the law does not permit parallel, duplicate investigations: the remedy is to have them clubbed into one, not to seek a blanket immunity from any future complaint on the same facts.

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

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