When Cheating Flows from One Criminal Conspiracy, the Law Does Not Demand 1852 FIRs: Supreme Court Upholds Single FIR in Multi-Crore Cheating Case

1852 Victims, One Scam, One FIR, On January 6, 2026, the Supreme Court delivered a landmark ruling in the case of The State (NCT of Delhi) v. Khimji Bhai Jadeja, affirming that a single FIR can legally cover multiple acts of cheating when they arise from a common criminal conspiracy, even if committed against numerous individuals. Terming the Delhi High Court's contrary view “erroneous” and “premature,” the Court clarified that unity of purpose or design, not the number of complainants or deposits, determines whether acts form part of the same transaction under criminal law.

The case arose from an elaborate fraudulent scheme where hundreds of individuals were allegedly duped into believing that a self-proclaimed godman, Ashok Jadeja, had divine powers to triple their money. Acting on this deception, 1,852 people deposited a total of ₹46.40 crores, all of which vanished. The Delhi Police registered one FIR, treated the additional complaints as Section 161 CrPC statements, and proceeded with a comprehensive investigation culminating in six supplementary chargesheets filed over the years.

The High Court, however, held that each deposit constituted a separate offence requiring a separate FIR, and ruled that the police could not treat other complainants as witnesses in a single FIR. This view was squarely rejected by the Supreme Court, which restored procedural coherence to mass fraud investigations.

“Unity of Purpose is a Strong Circumstance to Indicate One Transaction” – SC Reiterates Legal Standard for Consolidation of Offences

Justice Sanjay Kumar, writing for the Bench also comprising Justice Alok Aradhe, observed, “If several acts committed by a person show a unity of purpose or design, that would be a strong circumstance to indicate that those acts form part of the same transaction.” The Court reminded that the criminal conspiracy in this case was not a series of unrelated incidents but part of “a continuing scheme of inducement based on false spiritual claims.”

The Bench cautioned that the Delhi High Court's direction to register individual FIRs for each deposit would lead to a procedural nightmare. “Requiring registration of individual FIRs for each such complaint would lead to multiplicity of proceedings, which would be violative of public policy,” the Court remarked, underlining the need for judicial pragmatism in handling white-collar offences involving multiple victims.

“Consolidation is a Matter for the Magistrate After Investigation, Not During It” – Reference Under Section 395(2) Declared Premature

The Supreme Court also found fault with the Additional Sessions Judge who made the reference to the High Court under Section 395(2) CrPC during the pendency of investigation. The Court held, “The reference by the learned Additional Sessions Judge was premature, as the stage had not arisen for her to have entertained any doubt so as to raise the questions of law.”

It emphasized that the Magistrate is the competent authority to determine whether multiple offences can be tried together under Sections 220(1) and 223 of the CrPC, once the investigation is complete and chargesheets have been filed. The judgment noted, “As on date, as many as six supplementary chargesheets have been filed... and an offence under Section 120B IPC has been alleged. Therefore, the course adopted by the Delhi Police in registering one FIR and treating other complaints as statements under Section 161 CrPC was the correct course of action.”

“Even One FIR Doesn’t Rob Victims of Their Right to Protest” – SC Safeguards Complainants’ Role in Criminal Justice Process

Rejecting the High Court’s concern that treating victims as witnesses would deprive them of the right to oppose closure reports, the Supreme Court relied on precedent to state otherwise. “The complainants, who would then be treated as witnesses in relation to the FIR which was first registered, would be entitled to file protest petitions in the event of a closure report being filed or if the Magistrate is inclined to discharge the accused,” the Bench clarified. It reaffirmed that the Magistrate is bound to consider such protest petitions on merits, ensuring that consolidation does not mean erasure of victim agency.

“Multiplicity of Trials May Let the Guilty Go Free, Not Serve Justice” – SC Calls for Realism in Procedural Interpretation

In perhaps the most pragmatic articulation of the law, the Court observed that artificially fragmenting a continuing conspiracy into hundreds or thousands of FIRs could backfire. “If there is only one trial for such a conspiracy, in spite of separate offences being committed, it would enable the accused to go scot-free… which is not the intendment of law,” the judgment stated while cautioning against both extremes — unwarranted consolidation or mindless fragmentation.

The Court's view was grounded in precedent, citing decisions such as S. Swamirathnam v. State of Madras and Cheemalapati Ganeswara Rao, which held that multiple acts linked by a singular objective can be part of the same conspiracy. It also drew from Amish Devgan v. Union of India to reiterate that “when the subject matter of the FIRs is the same incident or part of the same transaction, separate FIRs are not warranted.”

“Proportionality of Punishment Will Be Decided at Trial Stage” – SC Rejects Fears of Sentence Dilution

On the issue of sentencing, the Court rejected the argument that clubbing offences into one FIR could allow the accused to escape harsher punishment. “The provisions of Section 71 IPC along with Sections 31 and 325 CrPC would have to be adhered to, depending upon the established facts and findings in the case,” held the Court. The Bench left it to the Trial Court to ensure that sentencing reflects the full extent of criminality, once guilt is established.

“Justice Demands Efficiency, Not Excessive Formalism” – Supreme Court Allows Appeal, Sets Aside High Court Ruling

Concluding that the Delhi High Court's ruling was legally unsustainable, the Supreme Court allowed the appeal, holding: “The judgment dated 08.07.2019 passed by the High Court of Delhi in Criminal Reference No. 1 of 2014 is set aside to the extent it answers Questions (a) and (b).”

It directed that the determination of whether offences form part of the same transaction must now be made by the Magistrate at the charge framing stage, based on the material gathered during investigation. The Bench also recorded its appreciation for Senior Advocate R. Basant, who served as amicus curiae and assisted the Court.

In setting aside an over-formalistic view of FIR registration and reaffirming a flexible, fact-based approach to complex conspiracy prosecutions, the Court has once again ensured that the law serves justice, not the other way around.

Date of Decision: January 6, 2026