Separate investor deposits in cheating cases are distinct transactions; common conspiracy alone cannot justify clubbing FIRs or charge-sheets.

In cheating and investment fraud matters, each investor's deposit is treated as a separate transaction where the inducement, deposit, time, place and victim are independently identifiable; a common conspiracy or similar modus operandi does not by itself make them one same transaction. Separate FIRs therefore cannot be clubbed into one FIR or merged into a single charge-sheet, because each FIR must result in its own final report, subject only to the limited joinder rules at the charge-framing stage. The theory of maximum punishment for one offence also cannot be used to collapse distinct deposits into a single case; sentencing depends on the offences actually proved.

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Issues: (i) Whether each deposit made by an investor in a cheating and investment fraud case constitutes a separate and individual transaction or can be clubbed into a single FIR on the basis of a common conspiracy; (ii) Whether, after separate transactions are treated as distinct, multiple such transactions can be amalgamated into one charge-sheet; (iii) Whether the concept of maximum punishment for a single offence can be invoked by clubbing all transactions into one FIR.

Issue (i): Whether each deposit made by an investor in a cheating and investment fraud case constitutes a separate and individual transaction or can be clubbed into a single FIR on the basis of a common conspiracy.

Analysis: The governing test for the same transaction is continuity of action and a real connection between the acts. Mere similarity of modus operandi, common design, or a broad conspiracy is not enough where each investor's inducement, deposit, amount, time, place, and victimhood are independent. A recurring series of similar cheating acts does not become one transaction merely because the overarching object is the same. The earlier authorities supporting clubbing were distinguished, while the later and more elaborate line of decisions treated each victim-specific deposit as an independent offence.

Conclusion: Each deposit by an investor constitutes a separate and individual transaction, and the transactions cannot be clubbed into one FIR by naming only one investor as complainant and the others as witnesses.

Issue (ii): Whether, after separate transactions are treated as distinct, multiple such transactions can be amalgamated into one charge-sheet.

Analysis: Registration of FIR triggers investigation, and each FIR must culminate in its own final report under the Code. The police cannot amalgamate separate cognizable offences investigated under separate FIRs into one charge-sheet. Section 219 applies only at the stage of framing of charge and permits joinder of not more than three offences of the same kind committed within twelve months, but it does not authorise the investigative agency to combine distinct FIRs or final reports into one charge-sheet.

Conclusion: Separate final reports are required for each FIR, and there is no question of amalgamating different final reports into one charge-sheet.

Issue (iii): Whether the concept of maximum punishment for a single offence can be invoked by clubbing all transactions into one FIR.

Analysis: Once each deposit transaction is treated as a distinct offence, the sentencing argument based on a single maximum punishment for one offence collapses. Sentencing must be determined by the trial court in accordance with the Code after conviction, taking into account the number and nature of offences actually proved and the provisions governing consecutive or concurrent sentences.

Conclusion: The single-offence maximum punishment theory cannot be pressed into service by clubbing distinct transactions into one FIR.

Final Conclusion: The reference was answered by holding that each investor's deposit-based cheating transaction is separate, each FIR requires its own final report, and the joinder provisions may be considered only at the charge-framing stage within the limits prescribed by law.

Ratio Decidendi: In cheating cases arising from multiple investor deposits, a common conspiracy does not by itself create one same transaction; continuity of action and factual interconnection are essential, and separate cognizable offences must be investigated and proceeded with separately, subject only to the limited joinder rules at the stage of charge.

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