Clubbing of multiple FIRs and conditional temporary bail were used to streamline proceedings and protect home buyers' claims.

Multiple FIRs arising from the same real estate transactions were clubbed to prevent fragmented criminal proceedings, with the earliest FIR treated as the main FIR and the remaining FIRs, including future ones on the same subject matter, treated as statements under Section 161 CrPC. Temporary release was also granted on strict conditions to allow the petitioner to arrange payment and settle claims with home buyers, while safeguarding their interests through financial compliance, surrender of passport, periodic police reporting, and non-alienation restrictions.

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Issues: (i) Whether all FIRs and criminal cases registered against the petitioner could be clubbed and treated through a main FIR mechanism. (ii) Whether the petitioner was entitled to temporary bail on conditions enabling deposit of the balance amount and settlement of claims with home buyers.

Issue (i): Whether all FIRs and criminal cases registered against the petitioner could be clubbed and treated through a main FIR mechanism.

Analysis: The petition arose from multiple FIRs arising out of the same broad set of transactions involving the petitioner's real estate ventures. The Court adopted a practical approach, noting the large number of home buyers affected and the need to avoid indefinite incarceration while protecting their interests. It directed that the earliest FIR would serve as the main FIR, and the remaining FIRs would be treated as statements under Section 161 of the Code of Criminal Procedure, 1973. Future FIRs on the same subject matter were also directed to be treated similarly.

Conclusion: The clubbing of all FIRs/criminal cases was allowed, with the earliest FIR treated as the main FIR and the others treated as statements under Section 161 of the Code of Criminal Procedure, 1973.

Issue (ii): Whether the petitioner was entitled to temporary bail on conditions enabling deposit of the balance amount and settlement of claims with home buyers.

Analysis: The Court took note of the petitioner's undertakings, the partial deposit already made, the disclosed properties, and the need to provide an opportunity to arrange settlement of the outstanding liability. Balancing the interest of the home buyers against the petitioner's prolonged custody, the Court granted release for a limited period subject to strict financial and non-alienation conditions, including surrender of passport and periodic police reporting.

Conclusion: Temporary bail for six months was granted, subject to the specified conditions and financial compliance.

Final Conclusion: The petition was substantially granted by ordering clubbing of the connected FIRs and permitting the petitioner's temporary release on stringent conditions to facilitate settlement with the affected home buyers.

Ratio Decidendi: Where multiple FIRs arise from the same transactional matrix affecting numerous victims, the Court may direct a main FIR arrangement and treat the others as statements to prevent fragmented criminal proceedings, while granting conditional relief to secure restitution and protect affected persons.

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