Multiple FIRs in consortium banking disputes may stand where each bank suffers a separate alleged offence despite a common conspiracy claim.

The one-FIR rule applies only where later complaints concern the same cognizable occurrence; where distinct offences emerge from separate transactions, multiple FIRs may stand. In a consortium banking arrangement, the Court noted that each bank had sanctioned separate credit facilities against separate work contracts, and that alleged cheating of each bank constituted a separate offence even if one larger conspiracy was alleged. As investigation was incomplete and charge-sheets had not been filed, the Court declined to record merits findings on the conspiracy at that stage. The request to quash, club, or treat the FIRs as one was rejected, and the separate FIRs were held maintainable.

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Issues: Whether multiple FIRs arising out of the consortium banking transaction could be quashed or clubbed and treated as a single FIR on the ground that they related to the same conspiracy and same transaction.

Analysis: The application was founded on the principle that there can be only one FIR for the same cognizable occurrence, but the Court held that the applicability of that rule depended on whether the later complaints were truly in respect of the same incident or disclosed distinct offences. On the material before it, the Court found that the representations were routed through the core committee acting for the member banks, that the individual banks had sanctioned separate credit facilities against separate work contracts, and that even on the assumption of one larger conspiracy the alleged cheating of each bank constituted a separate offence. The Court further held that, since investigation was incomplete and charge-sheets had not been filed, it was inappropriate to record findings on the merits of the alleged conspiracy at that stage.

Conclusion: The request to quash, club, or treat the FIRs as one was rejected, and the separate FIRs lodged by the respondent banks were held to be maintainable.

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