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Supreme Court of India 2026-01-06 allowed

State (NCT) of Delhi vs Khimji Bhai Jadeja

Bench: 2 — Sanjay Kumar, Alok Aradhe

In Brief

The Supreme Court set aside a Delhi High Court ruling that required separate First Information Reports (FIRs) for each victim in mass cheating cases. The case involved a fraud scheme where approximately 1,852 investors were cheated of ₹46.40 crore through false claims of divine money-multiplication powers. The Court held that when multiple acts of cheating stem from a single criminal conspiracy, a single FIR is legally permissible. The concept of "same transaction" depends on unity of purpose, continuity of action, and common design—not on the number of victims. Recording other complaints as witness statements under police procedure does not prejudice victims' rights, as they retain remedies like protest petitions at later stages. The ruling prioritizes investigative efficiency in large-scale economic offences.

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Criminal Procedure First Information Report Mass Cheating Criminal Conspiracy Economic Offences Joinder of Charges Same Transaction

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