In a significant ruling delivered on October 22, 2026, the Bombay High Court in Vishnu Ramchandra Bhagwat v. State of Maharashtra & Ors. (Criminal Writ Petition No. 1585 of 2023) allowed a petition seeking the consolidation and clubbing of ten separate First Information Reports (FIRs) registered against the petitioner across various police stations and economic offense wings in Maharashtra. Justice A.S. Gadkari and Justice Kamal Khata held that multiple proceedings arising from identical allegations of default on deposits by the same business entities should be tried together in the interest of justice and efficient administration.
Background
- The Entities and Allegations: The petitioner is a director and promoter of three business entities operating as cooperative credit societies and direct selling firms—specifically, (i) Ujjwal Agro Multi State Co-operative Society Private Limited, (ii) Shri Mauli Multi State Credit Co-operative Society Private Limited, and (iii) M/s Sankalp Sidhi Product Private Limited.
- The FIRS: Multiple FIRs (including C.R. No. 209 of 2019 registered at Mumbai Naka Police Station, Nashik, alongside nine other FIRs across Dhule, Ambad, Jaikheda, Pathardi, Parali, Phaltan, Bhandup, EOW Pune, and Ulhasnagar) were lodged against him under various sections of the IPC, the MPID Act, and the PCMC Act.
- The Core Grievance: The petitioner contended that all ten FIRs rested on identical allegations—namely, accepting deposits promising high returns and subsequently defaulting on payments after a debit freeze was placed on company bank accounts by the EOW. Arguing that he had already been granted bail in the respective cases, the petitioner sought clubbing to avoid defending multiple parallel trials across ten different courts.
Court’s Reasoning
1. Multiplicity of Proceedings Not in Public Interest
- Relying on established Supreme Court precedents—including State (NCT of Delhi) v. Khimji Bhai Jadeja, Radhey Shyam v. State of Haryana, and Alok Kumar v. State of Bihar—the High Court reaffirmed that multiplicity of proceedings regarding a common financial scheme or network is contrary to public interest.
- The Court noted that since all ten FIRs shared substantially identical allegations concerning the petitioner’s role as director of the same entities, consolidating the proceedings would streamline the trial process.
2. Treatment of Subsequent FIRs and Guidelines for Trial
- In alignment with apex court principles, the Court directed that the earliest FIR (C.R. No. 209 of 2019 registered with Mumbai Naka Police Station, Nashik) be treated as the main/lead case, while all subsequent FIRs and charge-sheets be transferred and treated as statements under Section 161 of the CrPC.
- To mitigate hardship for investors and witnesses, the Trial Court was permitted to record evidence via video conferencing where appropriate. Furthermore, the Court mandated that if witnesses are required to be physically present, the petitioner must bear all travel (AC train tickets), food, and lodging expenses (at least an ‘A-Grade’ hotel plus a daily allowance) to ensure witnesses do not suffer financial inconvenience.
Final Directions and Orders
The High Court allowed the writ petition and disposed of the pending interim application with the following explicit directions:
- Transfer of Cases: The Registrar (Judicial-I) was directed to ensure all courts transfer their respective charge-sheeted cases to the designated Special/Trial Court trying C.R. No. 209 of 2019 at Nashik within 30 days.
- Expense Compliance: The petitioner is strictly liable for travel, food, and accommodation expenses of physical witnesses as mandated by the court.
Citation: Vishnu Ramchandra Bhagwat v. State of Maharashtra & Ors. (Criminal Writ Petition No. 1585 of 2023)
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