Bombay High Court Refuses to Club Pune FIR With Three Mumbai FIRs in Medical Admission Scam; Orders Consolidation Only of Mumbai Cases and Rejects Blanket Bar on Future FIRs
Four FIRs Alleged Common Medical Admission Fraud; Bombay High Court Clubs Three Mumbai Cases but Declines Transfer of Pune FIR.
Facts
The petitioner approached the Bombay High Court under Article 226 seeking consolidation and transfer of four FIRs registered in Maharashtra alleging a large-scale medical admission fraud. The allegations were that students and parents were induced to pay substantial sums towards counselling fees, processing fees and college fees through Eduvio Learning Solutions Private Limited, operating under the trade name Eduvio NEET Counselling, on the promise of securing admission to medical colleges. The four FIRs comprised FIR No. 0301/2026 (Powai Police Station), FIR No. 0317/2026 (Andheri Police Station), FIR No. 0679/2026 (D.B. Marg Police Station) and FIR No. 0165/2026 (Yerwada Police Station, Pune).
The petitioner contended that all FIRs arose from the same business model and continuous course of conduct, involved common documentary and electronic evidence, and therefore required a single investigation to avoid duplication and conflicting findings. The petitioner also sought a direction restraining the police from registering any future FIRs arising from similar complaints and requested that future complaints be treated merely as witness statements under the BNSS.
Issues
- Whether all four FIRs should be clubbed and investigated together.
- Whether the Pune FIR should be transferred and consolidated with the Mumbai FIRs.
- Whether the Court could restrain registration of future FIRs concerning similar allegations.
- Whether consolidation was necessary to prevent duplication of evidence and multiple criminal trials.
Petitioner’s Arguments
The petitioner argued that the allegations in all four FIRs were not independent incidents but formed part of a single, continuing fraudulent business model involving medical admissions conducted through Eduvio NEET Counselling. According to the petitioner, the investigation in each FIR would necessarily involve the same bank accounts, electronic devices, digital communications, call records, social media accounts and documentary evidence. Separate investigations by different police stations would therefore result in overlapping investigations, duplication of evidence and the possibility of conflicting findings.
The petitioner further requested that the Court prevent registration of future FIRs arising from complaints concerning the same transactions and instead direct that such complaints be treated merely as statements of witnesses under the Bharatiya Nagarik Suraksha Sanhita, 2023. Reliance was placed upon the Supreme Court decisions in Odela Satyam v. State of Telangana and Abhishek Singh Chauhan v. Union of India in support of the relief sought.
Respondent’s Arguments
The State opposed the prayer seeking a blanket prohibition on registration of future FIRs, submitting that the Court could not determine in advance whether future complaints would arise from the same transaction or constitute separate offences. The prosecution contended that the petitioner would remain free to pursue remedies available under law if such FIRs were subsequently registered.
The State further informed the Court that investigation in the Mumbai FIRs had already been transferred to the Economic Offences Wing, Mumbai, and charge sheets in two FIRs had already been filed before the 37th Esplanade Court, Mumbai. It was submitted that while consolidation of the Mumbai FIRs might be appropriate, transfer of the Pune FIR would cause serious inconvenience and prejudice to complainants and witnesses residing in Pune.
Analysis of the Law
The Court considered the principles governing consolidation of multiple FIRs involving interconnected transactions. It observed that where investigations substantially overlap and involve common evidence, consolidation may be justified to avoid duplication of investigation, repeated evidence and multiple trials. However, such relief must be balanced against practical considerations, including convenience of witnesses and complainants.
The Court also examined the Supreme Court decisions in Odela Satyam, Amandeep Singh Saran, and Abhishek Singh Chauhan. It clarified that courts cannot grant blanket directions restraining registration of future FIRs because it is impossible to determine in advance whether future complaints concern the same transaction or distinct offences. The Court further noted that the relief granted in Abhishek Singh Chauhan arose from the Supreme Court’s exercise of its extraordinary powers under Article 142 and could not be mechanically applied in every case.
Precedent Analysis
- Odela Satyam & Anr. v. State of Telangana, 2025 SCC OnLine SC 2080 – Relied upon to reiterate that courts cannot issue blanket directions prohibiting registration of future FIRs.
- Amandeep Singh Saran v. State of Delhi, 2023 SCC OnLine SC 1851 – Followed by the Supreme Court in Odela Satyam to hold that advance restraint on future FIRs is impermissible.
- Abhishek Singh Chauhan v. Union of India, 2022 SCC OnLine SC 1936 – Distinguished on the ground that consolidation and bail were granted by the Supreme Court while exercising Article 142 jurisdiction with the consent of the concerned State.
Court’s Reasoning
The Division Bench noted that investigation of the Mumbai FIRs had already been transferred to the Economic Offences Wing and that charge sheets in two FIRs had already been filed before the same court, while the third Mumbai FIR was also expected to culminate before that court. In these circumstances, consolidation of the three Mumbai FIRs would avoid duplication of evidence, prevent multiple trials and promote the interests of justice.
However, the Court accepted the State’s submission that transferring the Pune FIR to Mumbai would unnecessarily prejudice complainants and witnesses residing in Pune by compelling them to travel for criminal proceedings. Accordingly, the Pune FIR was permitted to continue independently. The Court also rejected the petitioner’s request for a blanket prohibition against registration of future FIRs, holding that such a direction would be contrary to binding Supreme Court precedent and that it was impossible to determine whether future complaints would involve the same or independent transactions. The petitioner was instead granted liberty to challenge any future FIRs through appropriate legal proceedings if circumstances warranted. Finally, the Court clarified that it had expressed no opinion on the merits of the allegations and that the investigating agency and trial courts would remain free to proceed in accordance with law.
Conclusion
The Bombay High Court partly allowed the writ petition by directing consolidation of the three Mumbai FIRs while declining to transfer or club the Pune FIR. It further refused to grant a blanket injunction restraining future FIRs, holding that such relief was impermissible under settled Supreme Court precedent. The petitioner retained liberty to challenge any future proceedings in accordance with law.
Case Details
- Case: Argonda Arvind @ Adithya Prakash Kumar v. State of Maharashtra & Ors.
- Court: Bombay High Court
- Case Number: Writ Petition (Stamp) No. 11986 of 2026
- Judges: Acting Chief Justice Ravindra V. Ghuge and Justice Gautam A. Ankhad
- Date: 28 July 2026
- Result: Writ petition partly allowed; three Mumbai FIRs ordered to be clubbed and consolidated, Pune FIR retained separately, and prayer seeking blanket restraint on future FIRs rejected.
