State-wise consolidation of multiple FIRs: later complaints become statements, with supplementary investigation and bail consequences aligned.

Multiple FIRs arising from the same course of conduct should be consolidated State-wise with the earliest FIR in the concerned State, rather than transferred outside the State, because multiplicity of proceedings is not in the larger public interest and special enactment matters should proceed before the competent Special Court. After clubbing, the first FIR becomes the principal FIR, later FIRs are treated as statements under Section 161 CrPC, and the investigating officer may file supplementary charge-sheets using material from the merged FIRs. If cognizance has already been taken, those matters also merge with the principal FIR, and bail granted in the principal matter extends to the clubbed matters, subject to a fresh application where different special-law offences are involved.

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Issues: (i) Whether multiple FIRs registered in different States arising out of the same course of conduct should be consolidated by merging them with the earliest FIR in each State rather than being transferred out of the State. (ii) Whether, after such clubbing, the subsequent FIRs should be treated as statements, and how pending cognizance, supplementary investigation, and bail consequences should operate.

Issue (i): Whether multiple FIRs registered in different States arising out of the same course of conduct should be consolidated by merging them with the earliest FIR in each State rather than being transferred out of the State.

Analysis: The governing approach is that multiplicity of proceedings is not in the larger public interest. Where special State enactments concerning deposits and allied offences are invoked, shifting the cases out of the State would not serve the ends of justice. The appropriate course is to merge the later FIRs with the earliest FIR within the concerned State, and where the first FIR is under the general penal law but later FIRs invoke a special enactment, the clubbed matter must proceed under the special law before the competent Special Court.

Conclusion: The FIRs were directed to be merged State-wise with the earliest FIR in each concerned State, and not transferred outside the State.

Issue (ii): Whether, after such clubbing, the subsequent FIRs should be treated as statements, and how pending cognizance, supplementary investigation, and bail consequences should operate.

Analysis: After clubbing, the first FIR is to be treated as the principal FIR and the later FIRs are to be treated as statements under Section 161 of the Code of Criminal Procedure, 1973. The investigating officer in the principal FIR is permitted to file supplementary charge-sheets after collating the materials from the clubbed FIRs. If police reports have already been filed in the clubbed matters and cognizance has been taken, those cases also stand transferred and merged with the principal FIR. The order also clarifies that bail granted in the principal matter will enure to the benefit of the clubbed matters, subject to the need for a fresh application where different offences under a special enactment are involved.

Conclusion: The subsequent FIRs were ordered to be treated as statements, pending cases were directed to merge with the principal FIR, and the ancillary investigation and bail directions were issued accordingly.

Final Conclusion: The writ petition succeeded with State-wise consolidation of the connected FIRs into principal FIRs, together with consequential directions for investigation, trial, and bail.

Ratio Decidendi: Where multiple FIRs arise from the same transaction or connected conduct within a State, the proper course is State-wise consolidation with the earliest FIR, and the clubbed proceedings must continue under the legal regime attracted by the principal and subsequently clubbed offences.

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