Consolidation of multiple FIRs allowed for Bike Bot scheme matters, with merger of chargesheets and trials into one composite proceeding.

Multiple FIRs arising from the Bike Bot scheme were directed to be consolidated with the principal FIR so that the matter could proceed as one composite investigation and trial. Applying Article 142 of the Constitution and the principle against multiplicity of proceedings in appropriate cases, the SC ordered that the connected FIRs, including the Delhi FIR, would merge into the principal FIR. Chargesheets already filed in the separate cases would stand merged with the principal chargesheet, and a supplementary composite chargesheet could be filed to include statements recorded in the connected matters. Where cognizance had already been taken separately, those cases would be transferred and merged with the trial from the principal FIR.

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Issues: Whether multiple FIRs arising out of the Bike Bot scheme could be consolidated with the principal FIR and proceeded with as one composite investigation and trial.

Analysis: The relief was confined to clubbing of FIRs. The Court, applying Article 142 of the Constitution of India and following the principle against multiplicity of proceedings in appropriate cases, held that the FIRs, including the Delhi FIR, could be consolidated with the principal FIR. It further directed that chargesheets already filed in other cases would stand merged with the chargesheet in the principal FIR, and that a supplementary composite chargesheet could be filed to incorporate statements recorded in the connected matters. Where cognizance had already been taken in the separate cases, those matters would stand transferred and merged with the trial arising from the principal FIR.

Conclusion: Consolidation of all FIRs with the principal FIR was allowed, with consequential merger of existing chargesheets and trials.

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