Legal Analysis: Amit Katyal & Anr. v. State of Haryana & Anr

Citation: 2026 INSC 509
Court: Supreme Court of India
Bench: A Division Bench comprising Justice Prasanna B. Varale and Justice Pankaj Mithal
Date of Decision: May 18, 2026
Nature of Case: Writ Petition (Criminal) No. 67 of 2025 under Article 32 of the Constitution of India

Synopsis

The petitioners, directors of a real estate company, were facing multiple First Information Reports (FIRs) registered in Delhi and Haryana arising out of the same real estate project “Brahma City/Krrish World”. The FIRs alleged cheating, criminal breach of trust, and misappropriation of funds received from homebuyers. The petitioners sought clubbing/transfer of the subsequent FIR (No. 439/2024, Gurugram) with the earlier FIR (No. 30/2019, EOW Delhi) and a blanket direction restraining coercive action in any future FIRs based on the same transaction. The Supreme Court partly allowed the writ petition, holding that under the scheme of the Code of Criminal Procedure, 1973, only the earliest FIR in respect of a cognizable offence or occurrence is maintainable; subsequent FIRs for the same transaction are impermissible. The Court directed clubbing of the two FIRs for investigation but declined to grant a blanket protection against future FIRs.

1. Basic Information of the Judgment

• Case Title: Amit Katyal & Anr. v. State of Haryana & Anr.

• Citation: 2026 INSC 509

• Writ Petition (Criminal) No.: 67 of 2025

• Bench: Division Bench (Justice Prasanna B. Varale and Justice Pankaj Mithal)

• Date of Decision: May 18, 2026

• Court: Supreme Court of India (Criminal Original Jurisdiction)

• Nature of Petition: Writ petition under Article 32 of the Constitution

2. Legal Framework

Major Laws and Provisions Involved

• Constitution of India, 1950 – Article 32 (writ jurisdiction of Supreme Court for enforcement of fundamental rights).

• Code of Criminal Procedure, 1973 (CrPC) – Sections 154 (information in cognizable cases – FIR), 156 (investigation), 157

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