If many people are cheated under one common conspiracy, the police can register only one FIR. Separate FIRs for each victim are not compulsory.

Case at a Glance

  • Case: State (NCT of Delhi) v. Khimji Bhai Jadeja
  • Court: Supreme Court of India
  • Year: 2026
  • Topic: FIR, conspiracy, mass cheating

Background of Case

The accused claimed to possess divine powers and promised investors that their money would be tripled. Trusting these claims, 1,852 investors invested their savings. It was later alleged that the scheme was fraudulent, involving around ₹46.40 crore. The police registered one FIR, and statements of the remaining investors were recorded under Section 161 CrPC.

The Legal Question

When many people are cheated, should the police register separate FIRs for each victim?

What the Delhi High Court Said Earlier

The Delhi High Court said:

  • Each investor’s deposit is a separate transaction
  • So, separate FIRs are required
  • All complaints cannot be combined into one FIR

What the Supreme Court Held

The Supreme Court disagreed.

Supreme Court’s Clear View

  • When cheating happens due to one conspiracy
  • And all acts are connected
    One FIR is legally valid

The Court said that this decision cannot be forced at the FIR stage.

How to Decide “Same Transaction”?

The Court repeated the standard tests (any one is enough):

  • Same purpose (one common plan)
  • Continuous actions
  • Close time and place

These factors are examined after investigation, not before it.

What About Other Victims?

The Court clarified:

  • Victims are not helpless
  • They can:
    • File protest petitions
    • Challenge closure reports
    • Raise objections during trial

Does One FIR Mean Lesser Punishment?

❌ No.

The Court said:

  • Punishment is decided during trial
  • FIR registration does not control sentencing
  • Courts will apply Section 71 IPC and Section 31 CrPC as required

Final Result

  • Delhi High Court’s view was set aside
  • State’s appeal was allowed
  • Trial court will decide later whether charges should be combined or separated

LegalRath One-Line Revision

Many victims do not mean many FIRs.
One conspiracy can justify one FIR.