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The State (NCT) of Delhi v. Khimji Bhai Jadeja

Not available · 2026 INSC 25Decided 6 Jan 2026
Not available
Justice Sanjay Kumar · Justice Alok Aradhe

Background

Police treated 1,851 of 1,852 alleged fraud victims as witnesses under a single FIR rather than filing separate FIRs; a trial court referred legal questions about this to the High Court, which required separate FIRs per victim.

Decision Breakdown

The Supreme Court held one FIR was appropriate at that stage given the single alleged conspiracy, restated the flexible tests for what counts as "the same transaction," and clarified it's ultimately for the Magistrate to decide, at charge-framing, whether joint or separate trials are needed, while confirming victims-as-witnesses retain rights to object if the case is later dropped.

Lesson Learnt

Police aren't required to file a separate FIR for every victim in a large fraud case, but affected victims retain the right to object later if the case against the accused is dropped.

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

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