Bombay HC Sends 10 FIR Cases Over Alleged High-Return Deposit Defaults by Co-Operative Society Promoter to One Nashik Court

The petitioner was an accused in C.R. No. 209 of 2019, registered with the Economic Offences Wing, Nashik, for alleged offences including cheating, criminal breach of trust and offences under the MPID Act and PCMC Act.

He sought the clubbing of ten other FIRs registered at different police stations and the trial of the cases at one place.

The petitioner contended that the FIRs involved substantially identical allegations: that he had accepted deposits on promises of high returns, made partial repayments and then stopped paying.

The Court found the allegations in all ten FIRs to be substantially the same.

Whether the ten FIRs alleging substantially similar deposit-taking and non-repayment could be clubbed and tried together with the case arising from C.R. No. 209 of 2019.

Whether the cases in which charge-sheets had been filed should be transferred to the court trying the case arising from C.R. No. 209 of 2019.

The Court applied the principle that, where multiple FIRs arise from substantially the same scheme or transaction, consolidation and trial before one court may avoid multiplicity of proceedings and promote efficient administration of justice.

It relied on State (NCT of Delhi) v. Khimji Bhai Jadeja, 2026 SCC OnLine 19, which discussed Supreme Court decisions permitting consolidation of FIRs in appropriate cases, including Radhey Shyam v. State of Haryana, 2022 SCC OnLine SC 1935, and Alok Kumar v. State of Bihar, 2025 SCC OnLine SC 1728.

The Court noted the approach in Alok Kumar that the earliest FIR may be treated as the main FIR and subsequent FIRs as statements under Section 161 of the Code of Criminal Procedure, 1973.

The Court compared the allegations in the ten FIRs and found them substantially alike: each concerned deposits allegedly accepted on promises of high returns, followed by partial payments and subsequent non-payment.

Applying the consolidation principles discussed in the cited Supreme Court decisions, it concluded that clubbing the cases would facilitate the efficient administration of justice and expedite the proceedings.

It therefore directed transfer of the charge-sheet cases to the court trying the case arising from the earliest FIR, C.R. No. 209 of 2019.

The Registrar (Judicial-I) was directed to forward the judgment to the courts where charge-sheets had been filed so that those cases could be transferred to the court trying C.R. No. 209 of 2019 at Nashik.

The trial court may consider recording witness evidence by video conference; where witnesses attend physically, the petitioner must bear the specified travel, food and accommodation expenses.

The transfer exercise was directed to be completed, preferably within 30 days of the judgment being uploaded, and the pending interim application was disposed of.