Multiple FIRs for identical transactions involving the same real estate project must be clubbed to prevent multiplicity.

The petitioners were directors of M/s Krrish Realtech Pvt. Ltd., a company that failed to deliver possession of plots in the "Brahma City/Krrish World" project.

This led to the registration of multiple FIRs across Delhi and Haryana alleging cheating, misappropriation, and siphoning of funds.

Specifically, FIR No. 30/2019 was registered with the Economic Offences Wing (EOW), Delhi, clubbing complaints from 83 homebuyers.

Subsequently, FIR No. 439/2024 was registered at PS Sector-65, Gurugram, Haryana, based on identical allegations regarding the same project.

The petitioners approached the Supreme Court under Article 32 seeking the clubbing/transfer of these FIRs to avoid multiplicity of proceedings and double jeopardy.

1. Whether multiple FIRs registered in different jurisdictions arising out of the same set of transactions/occurrences should be clubbed or transferred to a single investigating agency.

2. Whether the court should grant a blanket direction to prevent coercive action in respect of any future FIRs registered on the same transaction.

The Court primarily relied on the principle established in T.T. Antony v. State of Kerala, which prohibits the registration of a "second FIR" for the same cognizable offence or occurrence, as the Code of Criminal Procedure (CrPC) contemplates a single comprehensive investigation.

This doctrine was further supported by precedents in Arnab Goswami v. Union of India, Amish Devgan v. Union of India, and Mohd. Zubair v. NCT Delhi, reaffirming that subsequent information regarding the same transaction must be treated as statements under Section 162 CrPC rather than fresh FIRs.

The Court observed that a "common thread" exists across the FIRs in Delhi and Haryana, consisting of grievances from homebuyers regarding non-delivery of plots despite payment.

Applying the T.T. Antony rule, the Court reasoned that permitting parallel investigations into the same transaction by different agencies would lead to conflicting findings and manifest prejudice to the accused.

The Court noted that since the Haryana Police had already constituted a Special Investigation Team (SIT) and conducted extensive work, and the Delhi Police expressed "no objection" to a single agency investigation, consolidation was in the interest of justice.

However, the Court distinguished between existing and future FIRs, noting that a blanket stay on future coercive actions is legally impermissible as it would interfere with the statutory right of the police to investigate distinct potential offences.

Regarding the second issue, the Court declined the prayer for blanket protection against future FIRs but granted the petitioners liberty to seek legal remedies if fresh FIRs are registered on the same transaction.