Multiplicity of Proceedings Not in Larger Public Interest” – Supreme Court Rejects Transfer of FIRs Across States, Allows Consolidation in Madhya Pradesh

In a significant ruling, the Supreme Court today addressed the issue of consolidating FIRs registered in different states against an individual. The court, while exercising its powers under Article 142 of the Constitution, decided to consolidate various FIRs filed in Madhya Pradesh but rejected the transfer of cases from Karnataka and Jharkhand to Madhya Pradesh.

The case, titled “2023 INSC 1060,” involved petitioner Amanat Ali, who sought the consolidation of FIRs registered against him in Madhya Pradesh, Karnataka, and Jharkhand for similar offences. The petitioner argued that such a move was necessary for a fair and speedy trial and to avoid the multiplicity of legal proceedings.

In delivering the judgment, the bench comprising Justices B.R. Gavai and Aravind Kumar observed, “Multiplicity of the proceedings will not be in the larger public interest and State also.” This statement underlines the court’s approach to handling cases involving multiple FIRs across different jurisdictions.

While the court acceded to the request for consolidation of FIRs within Madhya Pradesh, it held firm against transferring cases from other states. The court’s decision was influenced by the practical challenges and inconvenience that would be faced by complainants and witnesses if required to travel across states for legal proceedings.

Date of Decision: December 11, 2023

Amanat Ali  VS State of Karnataka and others