ORDER : N. TUKARAMJI, J. 1. (a). Criminal Petition No. 5466 of 2024 has been filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter ‘BNSS, 2023’), seeking to quash the proceedings against Petitioners 1 to 4 (Accused Nos. 1, 3 to 5) in Calendar Case No. 20 of 2024, pending before the Metropolitan Sessions Judge, Nampally, Hyderabad. (b). Criminal Petition No. 5516 of 2024, also under Section 528 of BNSS, 2023, seeks similar relief for Petitioners 1 to 4 (Accused Nos. 1 to 4) in Calendar Case No. 22 of 2024 before the same court. (c). Criminal Petition No. 5504 of 2024, again under Section 528 of BNSS, 2023, seeks quashing of proceedings against Petitioners 1 to 4 (Accused Nos. 1 to 4) in Calendar Case No. 24 of 2024, also before the Metropolitan Sessions Judge, Nampally, Hyderabad. 2. In each of these cases, the petitioners are charged with offences under Sections 406 and 420 read with Section 34 of the Indian Penal Code, 1860 (‘IPC’), Section 76 of the Chit Funds Act, 1982, and Section 5 of the Telangana State Protection of Depositors of Financial Establishments Act, 1999 (‘TSPDFE Act’). 3. I have heard arguments of Mr. N. Naveen Kumar, learned counsel for the petitioners, and Mr. Jithender Rao Veeramalla, learned Additional Public Prosecutor for Respondent No. 1. Summary of Prosecution Cases: 4. (a). Calendar Case No. 20 of 2024 (Criminal Petition No. 5466 of 2024): Petitioner No. 1 approached the de facto complainant, representing that he operated a registered chit fund business with Vuppala Naveen Kumar under the name Sree Nagarjuna Enterprises, and requested the complainant to refer subscribers. The complainant got enrolled his wife and others as subscribers. After paying the required instalments, when the complainant’s wife sought to collect the prize amount, Petitioner No. 1 evaded payment. The complainant later learnt that other subscribers were similarly denied repayment, resulting in a collective financial loss exceeding Rs. 1 crore. Based on the police report, Crime No. 103 of 2022 was registered. (b). Calendar Case No. 22 of 2024 (Criminal Petition No. 5516 of 2024): The complainant, a Director of Coruscant Systems Private Limited, Hyderabad, participated in a chit operated by Nagarjuna Enterprises Chit and Finance Company. After making the necessary payments, he became the successful bidder in January 2021 and was entitled to Rs. 18,59,625/-. (b). Calendar Case No. 22 of 2024 (Criminal Petition No. 5516 of 2024): The complainant, a Director of Coruscant Systems Private Limited, Hyderabad, participated in a chit operated by Nagarjuna Enterprises Chit and Finance Company. After making the necessary payments, he became the successful bidder in January 2021 and was entitled to Rs. 18,59,625/-. However, when he approached Pavan Kumar Vuppala for payment, the amount was not paid and the latter absconded. Crime No. 90 of 2022 was registered by Mahankali Police Station, later re-registered as Crime No. 263 of 2022 by District Hyderabad Police Station CCS, EOW Team-VIII. (c). Calendar Case No. 24 of 2024 (Criminal Petition No. 5504 of 2024): The complainant alleged that Petitioner No. 1, Vuppala Ramesh, introduced Petitioner No. 2, Vuppala Pavan Kumar, and solicited investments in Sree Nagarjuna Enterprises, promising 1.5% monthly interest. The complainant and his wife deposited Rs. 25,00,000/- and joined a chit group for Rs. 5,00,000/-. Promissory notes were executed, but upon maturity, no payments were made. Cheques issued by the petitioners were dishonoured, prompting the complainant to file a police report. Crime No. 102 of 2022 was registered by Mahankali Police Station, later re-registered as Crime No. 262 of 2022 by District Hyderabad Police Station CCS, EOW Team-VIII. 5. Following investigation and examination of witnesses and documents, the prosecution concluded that the petitioners, with criminal intent, operated an unauthorized chit fund business, causing wrongful loss to the complainants and others by collecting large sums and insisting on re-depositing the chit maturity amount. Accordingly, charges were filed under Sections 406, 420 read with 120-B of IPC, Section 76 of the Chit Funds Act, 1982, and Section 5 of the TSPDFE Act. Petitioners' Contentions: 6. The petitioners argued that the other accused, not named in the police report, are merely family members uninvolved in the business; thus, proceedings against them are unjustified. They further contend that the same investigating agency has registered multiple FIRs and charge sheets based on identical facts and transactions, which is impermissible and constitutes an abuse of process, violating their fundamental rights under Articles 14, 19, 20(2), and 21 of the Constitution. The petitioners assert that only one FIR should have been registered, with subsequent complaints treated as statements under Section 161 CrPC, in line with Supreme Court precedent. The petitioners assert that only one FIR should have been registered, with subsequent complaints treated as statements under Section 161 CrPC, in line with Supreme Court precedent. They also argue that the allegations pertain to non-payment of prize money and that the Chit Funds Act, 1982, provides appropriate remedies before the Registrar of Chits. They claim no fraudulent or criminal intent is apparent to justify prosecution under Sections 406 and 420 IPC, and that invoking Section 5 of the TSPDFE Act is unwarranted, as the company is registered with the Registrar of Chits, even if the chit groups themselves are not. Prosecution's Response: 7. The Additional Public Prosecutor contends that multiple police reports reflect the pattern of fraudulent conduct by the accused and cannot be a ground for quashing proceedings. He asserts that the petitioners operated unregistered chit groups, making them liable under the Chit Funds Act. Furthermore, running a financial establishment and collecting investments in instalments qualifies for prosecution under the TSPDFE Act, as recognized in V. Revathi v. State of Andhra Pradesh (2011 SCC OnLine AP 1161). He also points out that the petitioners misrepresented their company as active and compliant, while records show it has been inactive since registration, indicating deliberate deception. Offering higher interest rates to attract investors further demonstrates intentional cheating and breach of trust. Finally, the investigation has revealed that Petitioners 2, 3, and 4 are not merely family members but active partners involved in decision-making and financial transactions. Therefore, the prosecution asserts that triable issues exist, and the petitions should be dismissed. 8. I have perused the materials on record. 9. The allegations clearly indicate that the petitioners were engaged in the business of chit funds under the guise of operating registered chit schemes. However, admittedly it was only the company that was formally registered, not the specific chit operations in question. It is further alleged that, after collecting funds and upon the maturity of the chit schemes, the petitioners defaulted on repayments, thereby causing financial loss to each of the de facto complainants. 10. A principal contention raised by the petitioners is that the registration of multiple First Information Reports (FIRs) amounts to an abuse of legal process. In this regard, it is essential to highlight the well-established legal principle that multiple FIRs are permissible when each complaint pertains to distinct transactions or grievances involving different victims. 10. A principal contention raised by the petitioners is that the registration of multiple First Information Reports (FIRs) amounts to an abuse of legal process. In this regard, it is essential to highlight the well-established legal principle that multiple FIRs are permissible when each complaint pertains to distinct transactions or grievances involving different victims. This legal position has been affirmed in several authoritative judgments. In T.T. Antony v. State of Kerala & Others, (2001) 6 SCC 181 , the Hon’ble Supreme Court held that a second FIR is impermissible in respect of the same incident or occurrence. Nonetheless, the Court implicitly acknowledged that separate FIRs are maintainable if they arise from independent and unconnected acts, even if involving the same accused. Likewise, in Surender Kaushik & Others v. State of U.P. & Others, (2013) 5 SCC 148 , the Supreme Court upheld the maintainability of multiple FIRs filed by different complainants based on distinct causes of action and emphasized that complaints against a common accused do not necessarily constitute a single offence merely because they involve the same individual(s). 11. In the present case, the petitioners are facing allegations of financial impropriety from multiple complainants, each of whom claims to have suffered loss through separate and individual transactions. Consequently, the registration of multiple FIRs is both legally and procedurally justified. 12. Another argument advanced by the petitioners is that the operation of chit fund businesses is governed exclusively by the Chit Funds Act, 1982, and that any violation arising within the scope of chit fund activities must be adjudicated solely under the provisions of that enactment. They contend that, therefore, invoking penal provisions under the Telangana State Protection of Depositors of Financial Establishments Act, 1999 (TSPDFE Act) is legally untenable in such cases. 13. However, the applicability of the TSPDFE Act to fraudulent chit fund operations is no longer res integra. This issue has been comprehensively addressed in V. Revathi v. The State of A.P., rep. by Public Prosecutor, High Court of Hyderabad , 2011 SCC OnLine AP 1025. In paragraphs 15 to 18 of that decision, the Court elaborated on the legal compatibility between both enactments and upheld the application of the TSPDFE Act in situations involving deceitful or illegal chit fund schemes. For better appreciation, the relevant paragraphs of the authority are extracted hereunder: “ 15. In paragraphs 15 to 18 of that decision, the Court elaborated on the legal compatibility between both enactments and upheld the application of the TSPDFE Act in situations involving deceitful or illegal chit fund schemes. For better appreciation, the relevant paragraphs of the authority are extracted hereunder: “ 15. It is contended for the Appellant that there are special enactments regulating chit fund transactions and that therefore the provisions of the 1999 Act cannot be applied to a chit fund transaction. Though the Andhra Pradesh Chit Funds Act 1971 (In short, the 1971 Act) and the Chit Funds Act 1982 (In short, the 1982 Act) are there for regulation of chit fund transactions, the 1999 Act is again a special enactment which was enacted for protection of depositors of financial establishments. Statement of objects and reasons appended to the 1999 Act reads as follows: “Instances have come to the notice of the State Government, wherein a number of unscrupulous financial establishments in the State are cheating innocent, gullible depositors by offering very attractive rates of interest collecting huge deposits and then vanishing suddenly. The depositors are being cheated and are put to grave hardship by losing their hard earned savings. To curb these malpractices, the State Government have decided to bring a law for protecting the interests of depositors of financial establishment in the State and for matters connected therewith or incidental thereto. The above issue was also discussed in a Conference of the State Chief Ministers and Finance Ministers presided by the Union Finance Minister on 14-09-1998 at Vignan Bhavan, New Delhi. The Union Finance Minister also desired that States should take expeditious steps for enacting legislation on the lines of “Tamilnadu Protection of Interests of Depositors (in Financial Establishments) Act, 1997, “to restore the confidence amongst the innocent depositors and also to serve as a deterrent against malpractices by such establishments during the course of acceptance of public deposits. To achieve the above object, the Government have decided to make a separate law by undertaking Legislation”. 16. There is no provision in the 1999 Act dealing with repeals and savings. The 1999 Act was enacted by the State Legislature in addition to and not in derogation of any existing law dealing with the subject. The State Legislature enacted the 1971 Act for regulation of chit funds in the state of Andhra Pradesh. 16. There is no provision in the 1999 Act dealing with repeals and savings. The 1999 Act was enacted by the State Legislature in addition to and not in derogation of any existing law dealing with the subject. The State Legislature enacted the 1971 Act for regulation of chit funds in the state of Andhra Pradesh. The 1971 Act was repealed by Section 90 of the 1982 Act passed by the Parliament. As per Section 1(3) of the 1982 Act, that Act comes into force on such date as the Central Government may by notification in the Official Gazette appoint and different dates may be appointed for different States. Under Section 89 of the 1982 Act, the State Government in consultation with Reserve Bank of India has to make rules by notification in the Official Gazette for giving effect to the provisions of that Act. So far the Government of Andhra Pradesh has not made any rules under Section 89 of the 1982 Act. Therefore, till coming into force of the 1982 Act by notifying rules by the State Government, the 1971 Act is deemed to be in force. 17. Section 56 of the 1971 Act deals with penalties for contravention of certain provisions of the said Act. Section 56 reads as follows: “Penalties:- (1) Whoever contravenes or abets the contravention of any of the provisions of sub-section (1) of Section 3 or Section 4, sub-section (1) of Section 7 shall be punishable with imprisonment for a term which may extend to one year or with fine which may extend to five hundred rupees or with both. Section 56 reads as follows: “Penalties:- (1) Whoever contravenes or abets the contravention of any of the provisions of sub-section (1) of Section 3 or Section 4, sub-section (1) of Section 7 shall be punishable with imprisonment for a term which may extend to one year or with fine which may extend to five hundred rupees or with both. (2) Any foreman- (a) who does not file the chit agreement under Section 9 or a copy of any document under Section 11, sub-section 2 of Section 20, sub-section (2) of Section 21, Section 29 or Section 32 within the period specified for such filing or within the further time allowed under Section 55 for such filing; or (b) who contravenes any of the provisions of Section 8, sub-sections (1), (2) and (6) of Section 12, Section 14, Section 15, Section 16, Section 18, Section 20, Section 21, Section 23, sub-section (4) of Section 25, Section 29, Section 35, Section 36, Section 37 and sub-section (4) of Section 51; or (c) who fails to comply with the requirements of the chit agreement regarding the date, time and place at which the chit is to be drawn; shall be punishable with fine which may extend to one hundred rupees. (3) Whoever in any document required by or for purposes of, any of the provisions of this Act, wilfully makes a statement false, in any material particulars knowing it to be false, shall be punishable with imprisonment for a term which may extend to one year or with fine which may extend to five hundred rupees or with both”. 18. There is no penal provision under the 1971 Act providing for punishment in case of ‘default’ committed by organizer/foreman of the chit by not paying prize amount to the successful highest bidder or in case the organizer/foreman of the chit absconds by discontinuing the chit during the course of its currency and by not repaying or refunding the subscription amounts already collected from the members. The 1971 Act predominantly deals with regulatory measures for starting chit fund business, for commencement of a chit and running of the chit till the end of the chit period. In case, the organizer/foreman of the chit commits ‘default’, no penal remedy is prescribed and no penal liability is attached to such organizer/foreman of the chit under the 1971 Act. The 1971 Act predominantly deals with regulatory measures for starting chit fund business, for commencement of a chit and running of the chit till the end of the chit period. In case, the organizer/foreman of the chit commits ‘default’, no penal remedy is prescribed and no penal liability is attached to such organizer/foreman of the chit under the 1971 Act. Similarly, even if the 1982 Act comes into force, it also does not contain any provision dealing with penal remedy against organizer/foreman of the chit and attaching penal liability for ‘default’ committed by such organizer/foreman of the chit. Therefore, I have no hesitation to conclude that the 1999 Act is equally applicable in the case of a chit fund transaction also in addition to applicability of the existing 1971 Act and also the 1982 Act as and when it comes into force.” 14. The conclusions reached by this Court in the aforementioned authority continue to remain good law and are binding precedents. Accordingly, the contention advanced by the petitioners questioning the imposition of penal liability for the alleged offences is without merit and cannot be sustained. 15. In light of the foregoing analysis, and considering the existence of specific allegations that disclose a prima facie case against the petitioners, this Court finds no substance in the grounds urged for quashing the proceedings. The contentions raised are, therefore, untenable. In this position, this court is of the considered opinion that the prayer for quashing the criminal proceedings is devoid of merit. 16. Consequently, Criminal Petition Nos. 5516, 5466, and 5504 of 2025 are hereby dismissed. Pending miscellaneous applications, if any, shall stand closed.