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Victims have long been ‘pushed into a corner’, says Supreme Court

The victims have always been pushed into a corner. Unfortunately, we have never thought of the victims,” Chief Justice of India (CJI) Surya Kant, heading a three-judge Bench, orally remarked. The court has previously endorsed that the conspiracy charge and the subsequent acts can be tried before different courts,” Justice Bagchi remarked. The Bench, however, acknowledged that recent amendments to criminal law reflected a growing recognition of victims’ rights within the criminal justice system. After the court indicated it was not inclined to club the FIRs, Mr. Lekhi sought permission to withdraw the plea, which the Bench granted.
The Supreme Court on Thursday (May 21, 2026) observed that there is a pressing need for the criminal justice system to adopt a more victim-centric approach while refusing to entertain a plea seeking the clubbing of FIRs registered across several States by an accused in a chit fund scam. “...You have taken money from poor people, and now you want us to ensure that you are provided the luxury of facing trial in one place... We have only been referring to accused-centric jurisprudence in criminal law. The victims have always been pushed into a corner. Unfortunately, we have never thought of the victims,” Chief Justice of India (CJI) Surya Kant, heading a three-judge Bench, orally remarked. The Bench, also comprising Justices Joymalya Bagchi and Vipul M. Pancholi, was hearing a petition filed by Upendra Nath Mishra, an accused in the multi-hundred-crore chit fund scam involving Micro Finance Limited, which was probed by the Central Bureau of Investigation (CBI). Senior advocate Aman Lekhi, appearing for the accused, contended that where multiple acts of inducement and cheating arise in pursuance of a larger criminal conspiracy, all such transactions could be clubbed into a single FIR. “I am not saying don’t prosecute. I am questioning the method of prosecution,” he submitted. The Bench, however, disagreed with the interpretation, observing that each overt act independently gives rise to territorial jurisdiction for trial. “When a criminal conspiracy results in some overt acts, each of those overt acts creates a separate jurisdiction for trial... The court has previously endorsed that the conspiracy charge and the subsequent acts can be tried before different courts,” Justice Bagchi remarked. The Chief Justice further pointed to the severe financial burden such a plea would impose on victims, many of whom were small investors residing in remote regions. “An investment of ₹10,000 by one individual, multiplied by thousands of people, may amount to crores for you. But for that poor individual, it is only ₹10,000, and he seeks recovery of only that amount. You want him to travel from a remote village in Odisha to Delhi or from Bombay... How are victims’ rights protected if courts entertain such prayers?”, he remarked. The Bench further observed that victims cannot be compelled to travel from one place to another for the convenience of the accused and that the accused must confront the extent of financial ruin inflicted upon vulnerable investors. “These were poor victims who were allured into investing their hard-earned money in your chit fund company...labourers, senior citizens, people who invested whatever little life savings they had, and now you want them to come and depose against you at a place of your choice... Go to various parts of the country and see the manner in which the victims were cheated,” the CJI added. The Bench, however, acknowledged that recent amendments to criminal law reflected a growing recognition of victims’ rights within the criminal justice system. After the court indicated it was not inclined to club the FIRs, Mr. Lekhi sought permission to withdraw the plea, which the Bench granted.
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<p>The Supreme Court on Thursday (May 21, 2026) observed that there is a pressing need for the criminal justice system to adopt a more victim-centric approach while refusing to entertain a plea seeking the clubbing of FIRs registered across several States by an accused in a chit fund scam.</p><p>“...You have taken money from poor people, and now you want us to ensure that you are provided the luxury of facing trial in one place... We have only been referring to accused-centric jurisprudence in criminal law. The victims have always been pushed into a corner. Unfortunately, we have never thought of the victims,” Chief Justice of India (CJI) Surya Kant, heading a three-judge Bench, orally remarked.</p><p>The Bench, also comprising Justices Joymalya Bagchi and Vipul M. Pancholi, was hearing a petition filed by Upendra Nath Mishra, an accused in the multi-hundred-crore chit fund scam involving Micro Finance Limited, which was probed by the Central Bureau of Investigation (CBI).</p><p>Senior advocate Aman Lekhi, appearing for the accused, contended that where multiple acts of inducement and cheating arise in pursuance of a larger criminal conspiracy, all such transactions could be clubbed into a single FIR. “I am not saying don’t prosecute. I am questioning the method of prosecution,” he submitted.</p><p>The Bench, however, disagreed with the interpretation, observing that each overt act independently gives rise to territorial jurisdiction for trial. “When a criminal conspiracy results in some overt acts, each of those overt acts creates a separate jurisdiction for trial... The court has previously endorsed that the conspiracy charge and the subsequent acts can be tried before different courts,” Justice Bagchi remarked.</p><p>The Chief Justice further pointed to the severe financial burden such a plea would impose on victims, many of whom were small investors residing in remote regions.</p><p>“An investment of ₹10,000 by one individual, multiplied by thousands of people, may amount to crores for you. But for that poor individual, it is only ₹10,000, and he seeks recovery of only that amount. You want him to travel from a remote village in Odisha to Delhi or from Bombay... How are victims’ rights protected if courts entertain such prayers?”, he remarked.</p><p>The Bench further observed that victims cannot be compelled to travel from one place to another for the convenience of the accused and that the accused must confront the extent of financial ruin inflicted upon vulnerable investors.</p><p>“These were poor victims who were allured into investing their hard-earned money in your chit fund company...labourers, senior citizens, people who invested whatever little life savings they had, and now you want them to come and depose against you at a place of your choice... Go to various parts of the country and see the manner in which the victims were cheated,” the CJI added.</p><p>The Bench, however, acknowledged that recent amendments to criminal law reflected a growing recognition of victims’ rights within the criminal justice system.</p><p>After the court indicated it was not inclined to club the FIRs, Mr. Lekhi sought permission to withdraw the plea, which the Bench granted.</p>
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Supreme Court bans FIR clubbing, pushes for victim‑centric criminal justice.

Key Facts

  1. Supreme Court delivered its verdict on 21 May 2026, refusing to club FIRs from different states in a chit‑fund fraud case.
  2. Chief Justice of India Surya Kant stressed the need for a victim‑centric approach in criminal law.
  3. The petition was filed by accused Upendra Nath Mishra in the multi‑hundred‑crore Micro Finance Limited chit‑fund scam investigated by the CBI.
  4. The Court held that each overt act of a conspiracy creates a separate territorial jurisdiction for trial.
  5. Victims were primarily small investors from remote areas such as villages in Odisha, many being labourers and senior citizens.
  6. Recent amendments to the Indian Penal Code and the Code of Criminal Procedure (2023‑24) have begun to recognise victims' rights.

Background & Context

The judgment highlights a shift from an accused‑centric to a victim‑centric criminal‑justice model, a theme covered under Polity and Criminal Justice reforms in GS‑2. It also underscores jurisdictional challenges in multi‑state financial frauds, linking law, governance and economic protection of vulnerable investors.

UPSC Syllabus Connections

GS4•Case Studies on ethical issuesGS2•Statutory, regulatory and quasi-judicial bodiesEssay•Philosophy, Ethics and Human Values

Mains Answer Angle

In Mains, candidates can discuss the need for victim‑centric reforms in the criminal justice system (GS‑2) and evaluate how the Supreme Court's stance can influence future legislation and judicial practice.

Analysis

Practice Questions

GS1
Easy
Prelims MCQ

Victim‑centric justice

1 marks
4 keywords
GS2
Medium
Mains Short Answer

Criminal justice reforms

5 marks
3 keywords
GS2
Hard
Mains Essay

Criminal justice and victim rights

20 marks
6 keywords
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Key Insight

Supreme Court bans FIR clubbing, pushes for victim‑centric criminal justice.

Key Facts

  1. Supreme Court delivered its verdict on 21 May 2026, refusing to club FIRs from different states in a chit‑fund fraud case.
  2. Chief Justice of India Surya Kant stressed the need for a victim‑centric approach in criminal law.
  3. The petition was filed by accused Upendra Nath Mishra in the multi‑hundred‑crore Micro Finance Limited chit‑fund scam investigated by the CBI.
  4. The Court held that each overt act of a conspiracy creates a separate territorial jurisdiction for trial.
  5. Victims were primarily small investors from remote areas such as villages in Odisha, many being labourers and senior citizens.
  6. Recent amendments to the Indian Penal Code and the Code of Criminal Procedure (2023‑24) have begun to recognise victims' rights.

Background

The judgment highlights a shift from an accused‑centric to a victim‑centric criminal‑justice model, a theme covered under Polity and Criminal Justice reforms in GS‑2. It also underscores jurisdictional challenges in multi‑state financial frauds, linking law, governance and economic protection of vulnerable investors.

UPSC Syllabus

  • GS4 — Case Studies on ethical issues
  • GS2 — Statutory, regulatory and quasi-judicial bodies
  • Essay — Philosophy, Ethics and Human Values

Mains Angle

In Mains, candidates can discuss the need for victim‑centric reforms in the criminal justice system (GS‑2) and evaluate how the Supreme Court's stance can influence future legislation and judicial practice.

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