Single FIR for multiple victims is valid; separate complaints are not required for every identified victim.

The applicant sought to quash an order dated 20.07.2022 passed by the learned 3rd Additional Chief Judicial Magistrate, Vadodara. Following an investigation into FIR C.R. No. 11196007220271 of 2022—which alleged cheating and criminal breach of trust under Sections 406, 420, 120B, 506(2), and 114 of the IPC—the Police filed a charge-sheet identifying 12 victims

Although the FIR was lodged by one complainant, it mentioned three other victims, and the investigation revealed eight more

The Magistrate, relying on a precedent, directed the police to file 11 separate FIRs and 11 separate charge-sheets for each of the other victims listed as witnesses in the current charge-sheet

1. Whether the Magistrate was legally justified in directing the filing of separate FIRs and charge-sheets for victims who were already cited as witnesses in a single consolidated charge-sheet

2. Whether the decision in Narinderjit Singh Sahni v. Union of India (2002) applied to the facts of the present case to mandate separate proceedings

The court examined the scope of Section 482 of the Code of Criminal Procedure, 1973 (CrPC) regarding the prevention of abuse of the process of law

It interpreted the application of the Supreme Court's ruling in Narinderjit Singh Sahni v. Union of India, 2002 (2) SCC 210, which dealt with the consolidation of multiple criminal cases lodged by different depositors at different places/stages

The court also relied on the principle that the trial court has the duty and authority to frame charges against an accused based on all evidence/statements of victims cited as witnesses in a single charge-sheet without necessitating multiple FIRs for the same transaction

The High Court found that the Magistrate misinterpreted the Sahni precedent. In Sahni, the investors had already filed separate complaints across different jurisdictions, whereas here, no other victims had come forward to lodge separate FIRs; they were instead identified by the Investigating Officer (IO) during the course of a single investigation

The Court reasoned that since the IO had already included these victims as witnesses in the charge-sheet, their grievances could be addressed during the framing of charges in the existing trial

The Court held that forcing the registration of 11 new FIRs and charge-sheets would lead to an unnecessary multiplicity of proceedings and an "abuse of process," as the allegations of all 12 victims arose from the same investigative trajectory

The High Court allowed the application and quashed the impugned order dated 20.07.2022. It directed that the trial proceed on the basis of the existing charge-sheet, ensuring that allegations regarding all cited victims are considered during the framing of charges. Rule was made absolute