Independent investor transactions under a common business scheme do not constitute a single transaction for trial quashment.

The applicant, Managing Director of Mahakaushal Plantations Limited, was accused in 93 criminal cases across various states following the company's failure to repay public deposits.

The applicant was incarcerated for approximately 11 years and 7 months between 1998 and 2010.

While the Supreme Court previously issued directions for the sequencing of trials and some cases resulted in acquittal or conviction, 15 complaint cases remain pending at Shahdol.

The applicant moved the High Court under Section 482 of the Cr.P.C. to quash these pending proceedings, arguing they constitute a "single transaction" and that further trial after decade-long incarceration violates his right to a speedy trial.

1. Whether the pending criminal cases against the applicant arise out of the "same transaction" so as to warrant their quashment to avoid multiplicity of proceedings.

2. Whether the continuation of these proceedings, in light of the applicant’s prior incarceration and the delay, constitutes an abuse of the process of law.

3. Whether the High Court should exercise its inherent jurisdiction under Section 482 Cr.P.C. to terminate the trials.

Sections 218 to 220 of the Cr.P.C., which govern the joinder of charges and the trial for more than one offence if they form part of the "same transaction".

Inherent powers under Section 482 Cr.P.C., which are to be used sparingly to prevent abuse of process or to secure the ends of justice.

Section 427 Cr.P.C. regarding concurrent sentencing and Section 428 Cr.P.C. regarding set-off of pre-conviction detention.

The fundamental right to a speedy trial under Article 21 of the Constitution of India.

The Court rejected the "same transaction" argument, holding that each depositor’s complaint involved distinct amounts, dates, and representations, thereby creating independent causes of action rather than a single continuous act.

It reasoned that proximity of time and unity of purpose must be interpreted in a narrow, immediate sense, which a general business scheme spanning years does not satisfy.

Regarding the 11-year incarceration, the Court noted this is a factor for sentencing post-conviction rather than a ground for pre-emptive quashment.

The Court further observed that the Supreme Court had previously reviewed the applicant’s situation but chose to sequence the trials rather than quash them, implying their legal maintainability.

Terminating the proceedings would deny individual victims their right to legal adjudication.

The petition under Section 482 Cr.P.C. was dismissed; however, the Court granted the applicant liberty to raise pleas of delay and concurrent sentencing before the Trial Courts and directed the Trial Courts to expedite the proceedings.