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Rutvij Bhagat Singh Wakhare v. The State of Maharashtra

Writ Petition (Civil) · 2026 INSC 740Decided 24 Jul 2026
Writ Petition (Crl.) No. 127 of 2026
Justice Sanjay Karol · Justice Augustine George Masih · Justice R. Mahadevan

Background

Multiple FIRs were registered against the petitioner in Maharashtra, Karnataka and Odisha, alleging that different complainants across these states were induced to part with money through cyber fraud, invoking IPC provisions on cheating, forgery and criminal intimidation along with Sections 43, 66(C) and 66(D) of the IT Act. The petitioner approached the Supreme Court directly under Article 32, seeking either to have all the FIRs quashed outright or, alternatively, to have them clubbed together and investigated as a single composite case by one agency, citing his ailing health (cardiac and diabetic conditions) that made facing proceedings in multiple states difficult.

Decision Breakdown

The Supreme Court declined to club or consolidate the FIRs, holding that each FIR was lodged by a different complainant induced to part with money in separate transactions, with no live link connecting the incidents beyond a similar modus operandi: the mere fact that some defrauded funds landed in the same bank account did not, by itself, make them part of one transaction. The Court held that the petitioner's health difficulties, while genuine, could not justify clubbing distinct offences, especially since doing so could cause hardship to the various complainants who would then have to chase a single distant proceeding. It also emphasised that investigation into cyber frauds involving multiple bank accounts and digital trails across jurisdictions was still at a nascent stage, and a composite investigation direction at this point could impede a fair and effective probe, particularly given that victims were often unsophisticated rural citizens targeted by such schemes. The writ petition was accordingly dismissed, with liberty reserved to the petitioner to pursue appropriate remedies before the proper forum.

Lesson Learnt

Multiple FIRs arising from similar-looking fraud schemes are not automatically clubbed into one investigation merely because the accused is common or the method is similar. Courts look for a genuine, provable link between the transactions themselves, and personal hardship to the accused is not by itself grounds to override that requirement.

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

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