Amit Katyal v. State of Haryana 2026 INSC 509 - Multiple FIRs - Consolidation
Code of Criminal Procedure 1973 - Section 154 -There cannot be multiple FIRs in respect of the same occurrence or transaction giving rise to cognizable offences. The scheme of the Code of Criminal Procedure postulates a single, comprehensive investigation, with liberty to the investigating agency to conduct further investigation and file supplementary reports, rather than permitting parallel and overlapping investigations in different fora. Permitting multiple FIRs and investigations in different jurisdictions on the same set of facts would not only be contrary to the settled legal position but would also result in avoidable multiplicity of proceedings, conflicting findings and serious prejudice to the accused. (Para 24-25) [Context: In this case, the Supreme Court held that FIR lodged in Gurugram and FIR lodged in EOW, Delhi arise from the same set of allegations and directed that the EOW, Delhi FIR be transferred and clubbed with the other FIR for investigation in Haryana.]
Case Info
Case name: Amit Katyal & Anr. v. State of Haryana & Anr.
Neutral citation: 2026 INSC 509
Coram: Justice Pankaj Mithal and Justice Prasanna B. Varale
Judgment date: 18 May 2026
Caselaws and citations referred:
- T.T. Antony v. State of Kerala, (2001) 6\ \text{SCC}\ 181
- Arnab Goswami v. Union of India, (2020) 14\ \text{SCC}\ 12
- Amish Devgan v. Union of India, (2021) 1\ \text{SCC}\ 1
- Mohd. Zubair v. NCT of Delhi, (2023) 16\ \text{SCC}\ 764
Statutes / laws referred:
- Constitution of India, Article 32
- Code of Criminal Procedure, 1973 – especially Sections 154, 155, 156, 157, 162, 169, 170, 173(2), 173(8)
- Indian Penal Code, 1860 – Sections 406, 409, 420, 120B
Brief summary (three sentences):The petitioners, directors of M/s Krrish Realtech Pvt. Ltd., sought clubbing/transfer of multiple FIRs registered in Delhi and Haryana arising from the same real-estate project “Brahma City / Krrish World,” to avoid multiplicity of proceedings and prejudice. Applying the principle in T.T. Antony that there cannot be multiple FIRs for the same occurrence or transaction, the Supreme Court held that FIR No. 439/2024 at PS Sector‑65, Gurugram and FIR No. 30/2019 at EOW, Delhi arise from the same set of allegations and directed that FIR 30/2019 be transferred and clubbed with FIR 439/2024 for investigation in Haryana. The Court, however, refused the prayer for a blanket order against coercive action in respect of any future FIRs, clarifying that if such FIRs are lodged on the same transaction, the petitioners may seek remedies available in law.