Supreme Court – Daily Orders
Ravinder Singh Sidhu vs The State Of Punjab on 6 August, 2026
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ITEM NO.31 COURT NO.14 SECTION X
S U P R E M E C O U R T O F I N D I A
RECORD OF PROCEEDINGS
Miscellaneous Application No. 1795/2026 in W.P.(Crl.) No. 394/2024
RAVINDER SINGH SIDHU PETITIONER(S)/
APPLICANT(S)
VERSUS
THE STATE OF PUNJAB & ORS. RESPONDENT(S)
IA No. 131590/2026 - APPROPRIATE ORDERS/DIRECTIONS
Date : 06-08-2026 This matter was called on for hearing today.
CORAM : HON'BLE MR. JUSTICE K.V. VISWANATHAN
HON'BLE MR. JUSTICE ARUN PALLI
For Petitioner(s) Mr. Mohit Paul, AOR
/Applicant(s) Ms. Rangoli Seth, Adv.
Mr. Rohit, Adv.
For Respondent(s) Mr. Siddhant Sharma, AOR
Mr. Vikram Choudhary, Adv.
Mr. Yashraj Singh Bundela, AOR
Mr. Arpit Garg, Adv.
Ms. Shrindhi Gupta, Adv.
Mr. Vinayak Sharma, Standing Counsel, Adv.
Mr. Ravinder Kumar Yadav, AOR
Mr. Yashvardhan Shah, Adv.
Ms. Kritika Yadav, Adv.
Mr. Sudarshan Singh Rawat, AOR
Mr. Sunny Sachin Rawat, Adv.
Mr. Vikash Negi, Adv.
UPON hearing the counsel the Court made the following
O R D E R
1. In the present miscellaneous application, notices were
issued to State of Chhattisgarh and State of Madhya Pradesh.
Signature Not Verified
Digitally signed by
NIRMALA NEGI
Date: 2026.08.08
2. Heard learned counsel for the parties.
13:39:09 IST
Reason:
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3. State of Chhattisgarh has responded stating that in FIR
No.6/2014 registered at P.S.Kotwali, Rajnandgaon District, the
applicant Ravinder Singh Sidhu, is not an accused. Hence, no
further directions are required insofar as State of
Chhattisgarh is concerned.
4. Insofar as State of Madhya Pradesh is concerned,
Mr.Yashraj Singh Bundela, learned counsel points out fairly
that, while the FIR(s) number(s) mentioned in the present
application (paragraph nos.7 & 10) is/are wrong, there are in
fact two other FIRs pending against the applicant Ravinder
Singh Sidhu, namely Crime/FIR No.254/2011 dated 29.05.2011
registered with Police Station Inderganj, District Gwalior,
Madhya Pradesh and there is one more FIR not mentioned in the
present application namely Crime/FIR No.342/2011 dated
16.06.2011 registered with Kotwali Police Station, District
Morena, Madhya Pradesh. These are on the same subject matter.
5. The original judgment of this Court clubbing the First
Information Report(s) was passed on 19.05.2025 and paragraph
14 of the said judgment dealt with State of Madhya Pradesh
which read as follows:-
“14. In the State of Madhya Pradesh, the following FIR
will now be merged with FIR No. 496/2018 dated
05.12.2018 registered at Jabalpur P.S. Lordganj.
Sr.No. FIR No. Date Police Station Place
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1 176/2020 24.05.2020 Kotwali Anuppur Anuppur
6. Further operative directions were given in paragraph 19,
20 and 21 of the said judgment, in the following terms:-
“19. The writ petition stands allowed in the above
terms. We further direct while the first FIR will be
treated as the First Information Report (hereinafter for
convenience called the ‘principal FIR’), the subsequent
FIRs in each State shall be treated as Statements under
Section 161 of the Code of Criminal Procedure, 1973
(CrPC). The Investigating Officer in the criminal case
arising out of the principal FIR in the concerned State
will be free to file supplementary chargesheets after
the collation of all records concerning other FIRs in
the concerned State which are clubbed in terms of this
order. We further direct that if Police Report under
Section 173 of CrPC stands already filed in the clubbed
FIRs and the concerned Courts have taken cognizance
thereof, the said FIRs and criminal cases would also
stand transferred and merged/clubbed along with the
principal FIR to be proceeded with in accordance with
law.
20. The investigating officer in the principal
proceedings will be free to file supplementary charge•-
sheet on the basis of the material collated during
investigation of other FIRs. We also make it clear that
the other offences not part of the special enactments
can also be tried by the Special Court under the
concerned State legislation. We also further direct that
in case the petitioner has been granted bail in
connection with the principal proceeding/criminal case
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to which the other cases have been clubbed, the bail so
granted must enure to the petitioner’s favour in the
other FIRs now clubbed as well. We further clarify that
if the principal FIR is limited to offence under the
general law/Penal Code but the subsequent FIRs contain
allegations attracting offences under the special
enactment or certain other IPC offences and if the bail
granted is only for some offences under the general law,
the Special Court is entitled to insist for a fresh bail
application to be filed by the petitioner in relation to
those offences including under the Special Act. The said
bail application(s) shall be decided on its own merits
in accordance with law.
21. We make it clear that our direction is confined to
the offences mentioned in the present order, namely, the
offences under the IPC and the concerned State enactment
mentioned herein.”
7. Thereafter, when certain further FIRs came to light, an
order was made by this Court on 08.01.2026 in Miscellaneous
Application No.2692/2025 inter alia in following terms:-
“13. In the facts and circumstances of this case and
more particularly keeping in mind the main Judgment and
Order dated 19-5-2025 passed by this Court, all the
FIRs, referred to above, in the chart, as above, are
ordered to be added in the main Judgment and Order dated
19-5-2025 and the very same relief granted in the main
Judgment shall also be applicable to the FIRs, referred
to above, in the chart.”
8. Keeping in line with the above directions, we direct that
Crime/FIR No.254/2011 dated 29.05.2011 registered with Police
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Station Inderganj, District Gwalior, Madhya Pradesh and
Crime/FIR No.342/2011 dated 16.06.2011 registered with Kotwali
Police Station, District Morena, Madhya Pradesh are ordered to
be read as part of the main judgment dated 19.05.2025. It is
pointed out that FIR No.254/2011, was earlier in point of time
to FIR No.176/2020 dated 24.05.2020, registered with Kotwali
Anuppur Police Station, Anuppur, however, since as early as on
19.05.2025, in the main judgment it was directed that said FIR
i.e. No.176/2020 dated 24.05.2020) to be treated as the first
initiation of the prosecution and the lead proceeding.
9. Applying the findings in paragraph 125 of the judgment in
the case of “Ameesh Devgan vs. Union of India” reported in
(2021) 1 SCC and direct that Crime/FIR No.254/2011 dated
29.05.2011 and Crime/FIR No.342/2011 which have now come to
light to be treated the statement under Section 161 of the
Code of Criminal Procedure. The Paragraph 125 of Ameesh Devgan
(supra) reads as under:-
“125. Lastly, we would also like to clarify that
Section 179 of the Criminal Procedure Code permits
prosecution of cases in the court within whose local
jurisdiction the offence has been committed or
consequences, have ensued. Section 186 of the Criminal
Procedure Code relates to cases where two separate g
charge-sheets have been filed on the basis of separate
FIRs and postulates that the prosecution would proceed
where the first charge-sheet has been filed on the
basis of the FIR that is first in point of time.
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Principle underlying Section 186 can be applied at the
pre-charge-sheet stage, that is, post registration of
FIR but before charge-sheet is submitted to the
Magistrate. In such cases ordinarily the first FIR,
that is, the FIR registered first in point of time,
should be treated as the main FIR and others as
statements under Section 162 of the Criminal Procedure
Code. However, in exceptional cases and for good
reasons, it will be open to the High Court or this
Court, as the case may be, to treat the subsequently
registered FIR as the principal FIR. However, this
should not cause any prejudice, inconvenience or
harassment to either the victims. witnesses or the
person who is accused. We have clarified the aforesaid
position to avoid any doubt or debate on the said
aspect.”
10. We have treated this as an exceptional situation since
the original directions given in the main judgment were given
as early as on 19.05.2025 and the Investigating Agency
concerned and the accused have adjusted their affairs
accordingly.
11. With the above observations, the IA No.131590/2026 and
miscellaneous application are disposed of.
12. Pending application(s),if any, shall also stand disposed
of.
(NIRMALA NEGI) (MANOJ KUMAR) ASTT. REGISTRAR-cum-PS COURT MASTER (NSH)
