The Supreme Court on May 18 directed that an FIR registered by the Delhi Economic Offences Wing against directors of M/s Krrish Realtech Pvt. Ltd. be transferred and clubbed with a later FIR lodged in Gurugram, Haryana concerning the same “Brahma City/Krrish World” real estate project.
A Bench of Justice Pankaj Mithal and Justice Prasanna B. Varale held that permitting multiple FIRs arising from the same transaction would lead to overlapping investigations, conflicting findings and prejudice to the accused.
The petition was filed by Amit Katyal and another petitioner associated with M/s Krrish Realtech Pvt. Ltd. under Article 32 of the Constitution seeking transfer and clubbing of several FIRs registered in Delhi and Haryana over the delayed “Brahma City/Krrish World” housing project in Gurugram.
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According to the case record, the company had accepted bookings from homebuyers for plots and flats but allegedly failed to deliver possession or refund the invested amounts after the project stalled.
Several FIRs were subsequently registered by the Delhi Economic Offences Wing between 2016 and 2022 alleging cheating, criminal breach of trust and misappropriation of homebuyers’ funds.
The dispute later expanded to Haryana after another FIR, numbered 439/2024, was lodged at Sector-65 Police Station, Gurugram on allegations that the accused had cheated homebuyers and diverted money through shell companies.
Senior counsel appearing for the petitioners argued that FIR No. 30/2019 registered by the Delhi EOW had already consolidated complaints of 83 homebuyers and that subsequent FIRs were based on identical allegations.
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The petitioners contended that facing investigations in multiple states for the same transaction amounted to serious prejudice and exposed them to repeated coercive action.
Opposing the plea, Additional Solicitor General S.V. Raju, appearing for Haryana, argued that the allegations involved cheating of numerous homebuyers across different states and required a detailed probe by the Haryana SIT.
ASG Aishwarya Bhati, appearing for Delhi Police, informed the Court that Delhi Police had no objection if one agency conducted the investigation.
The Bench relied heavily on the Supreme Court’s ruling in T.T. Antony v. State of Kerala, reiterating that there cannot be multiple FIRs concerning the same occurrence or transaction.
The Court observed:
“Permitting multiple FIRs and investigations in different jurisdictions on the same set of facts would not only be contrary to the settled legal position but would also result in avoidable multiplicity of proceedings, conflicting findings and serious prejudice to the petitioners.”
The Bench also noted that one earlier FIR registered in Delhi had resulted in a cancellation report after investigators concluded the dispute appeared civil in nature.
Allowing the plea partly, the Supreme Court directed that FIR No. 30/2019 registered with the Economic Offences Wing, Delhi shall stand transferred and clubbed with FIR No. 439/2024 registered at Sector-65 Police Station, Gurugram.
However, the Court declined the petitioners’ request for blanket protection against future FIRs, clarifying that they could pursue remedies available under law if similar FIRs were lodged later.
The writ petition was accordingly partly allowed and pending applications were disposed of.
Case Title: Amit Katyal & Anr. v. State of Haryana & Anr.
Case Number: Writ Petition (Crl.) No. 67 of 2025
Court: Supreme Court of India
Bench: Justice Pankaj Mithal and Justice Prasanna B. Varale
Date: May 18, 2026
