Where many FIRs against the same person allege substantially the same scheme, such as a deposit scheme with promised high returns followed by non-payment, the High Court can club them for a common trial in one court, as multiplicity of proceedings is against the public interest and delays trials. The first FIR is treated as the main FIR, and the others as statements under Section 161 CrPC. Because the accused benefits from this, the court may impose conditions to protect the witnesses, such as video conferencing and payment of their expenses.
The Bombay High Court has ordered ten cases against Nashik businessman Vishnu Ramchandra Bhagwat to be clubbed and tried together in Nashik. They arise from deposit and investment schemes run by three entities he promoted: Ujjwal Agro Multi State Co-operative Society, Shri Mauli Multi State Credit Co-operative Society and Sankalp Siddhi Products. The first FIR, C.R. No. 209 of 2019, was registered by the Economic Offences Wing, Nashik, under Sections 406, 409, 420, 467, 468, 201 and 120B IPC, and provisions of the MPID Act and the Prize Chits and Money Circulation Schemes (Banning) Act. The ten FIRs, from police stations in Dhule, Nashik, Ahilyanagar, Beed, Satara, Mumbai and Thane, all alleged that he took deposits promising high returns, paid part of them and then stopped paying. His lawyer said that there had been no complaints until an RTI activist, whom he described as someone facing extortion and Arms Act cases, started a campaign that led to a debit freeze on the accounts, and the delay in payments led to the complaints. He pointed out that the alleged amount in the first FIR was Rs 5.87 crore, against assets worth over Rs 40 crore attached, that he had been in custody for over four years, and that he had got bail in each case. Justices A.S. Gadkari and Kamal Khata followed the Supreme Court’s recent approach in Khimji Bhai Jadeja, Alok Kumar, Amanat Ali, Radhey Shyam and Amish Devgan, under which multiple FIRs on the same scheme are clubbed, since multiplicity of proceedings is against the public interest. They found that the allegations in all ten FIRs are substantially the same, and that clubbing would speed up the trials. The Registrar (Judicial-I) must send a copy of the order to all the courts where charge-sheets have been filed, to transfer those cases to the Nashik court trying the first FIR, preferably within 30 days. Witnesses may be allowed to depose by video conference, and where they must attend in person, the petitioner must bear the travel (cheapest AC rail fare), Rs 2,000 a day for food and stay in an A-grade hotel.
Citation: Vishnu Ramchandra Bhagwat v. State of Maharashtra & Ors., Writ Petition No. 1585 of 2023 (with Interim Application No. 4330 of 2025), Bombay High Court (Justices A.S. Gadkari and Kamal Khata), decided on 22.10.2026 | 2026:BHC-AS:43004-DB
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