Article 32 Not the Appropriate Forum for Quashing FIRs; Multiple Cyber Fraud Complaints Not Clubbable

Case Snapshot

• Case Name: Rutvij Bhagat Singh Wakhare v. State of Maharashtra & Ors.

• Citation: 2026 INSC 740

• Bench: Justice Sanjay Karol and Justice Augustine George Masih

• Date of Judgment: July 23, 2026

• Area of Law: Constitutional Law, Criminal Procedure, Cyber Crime

Judgment in Brief

The Supreme Court dismissed the writ petition filed under Article 32 of the Constitution seeking quashing or clubbing of multiple FIRs registered in Maharashtra, Karnataka, and Odisha against the petitioner for cyber fraud. The Court held that Article 32 petitions for quashing FIRs are maintainable only in exceptional cases involving clear violation of fundamental rights. Since the petitioner failed to establish any infringement of fundamental rights or exceptional circumstances, he was relegated to pursue remedies under Article 226 or Section 482 of the Code of Criminal Procedure, 1973. The Court also rejected the prayer for clubbing the FIRs, holding that they relate to distinct transactions with different complainants and separate offences. The mere similarity in modus operandi does not make them part of the same transaction. The investigation being in its nascent stage, clubbing would impede effective investigation.

Relevant Facts

• The petitioner's proprietary concern, 'M/s Al Zeba Marinen Overseas,' maintained a bank account. The petitioner allowed his friend, Mr. Ganesh Khaire, to use the account for an online gaming business on a commission basis.

• Multiple FIRs were registered in Maharashtra (Pune), Karnataka (Bengaluru), and Odisha (Rourkela) for cyber fraud. The complainants were induced to transfer money by persons posing as police officials, falsely alleging money laundering activities.

• A part of the defrauded money was credited to the petitioner's bank account.

• The petitioner denied involvement and claimed he had lodged a cyber complaint against the persons who misused his account.

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