Trial for more than one offence
Section 243 of the Bharatiya Nagarik Suraksha Sanhita, 2023 deals with trial for more than one offence. If, in one series of acts so connected together as to form the same transaction, more offences than one are committed by the same person, he may be charged with, and tried at one trial for, every such offence. The Act came into force on 01 Jul 2024.
(1) If, in one series of acts so connected together as to form the same transaction, more offences than one are committed by the same person, he may be charged with, and tried at one trial for, every such offence.
(2) When a person charged with one or more offences of criminal breach of trust or dishonest misappropriation of property as provided in sub-section (2) of section 235 or in sub-section (1) of section 242, is accused of committing, for the purpose of facilitating or concealing the commission of that offence or those offences, one or more offences of falsification of accounts, he may be charged with, and tried at one trial for, every such offence.
(3) If the acts alleged constitute an offence falling within two or more separate definitions of any law in force for the time being by which offences are defined or punished, the person accused of them may be charged with, and tried at one trial for, each of such offences.
(4) If several acts, of which one or more than one would by itself or themselves constitute an offence, constitute when combined a different offence, the person accused of them may be charged with, and tried at one trial for the offence constituted by such acts when combined, and for any offence constituted by any one, or more, of such acts.
(5) Nothing contained in this section shall affect section 9 of the Bharatiya Nyaya Sanhita, 2023.
Illustrations to sub-section (1)
(a) A rescues B, a person in lawful custody, and in so doing causes grievous hurt to C, a constable in whose custody B was. A may be charged with, and convicted of, offences under sub-section (2) of section 121 and section 263 of the Bharatiya Nyaya Sanhita, 2023.
(b) A commits house-breaking by day with intent to commit rape, and commits, in the house so entered, rape with B's wife. A may be separately charged with, and convicted of, offences under section 64 and subsection (3) of section 331 of the Bharatiya Nyaya Sanhita, 2023.
(c) A has in his possession several seals, knowing them to be counterfeit and intending to use them for the purpose of committing several forgeries punishable under section 337 of the Bharatiya Nyaya Sanhita, 2023. A may be separately charged with, and convicted of, the possession of each seal under sub-section (2) of section 341 of the Bharatiya Nyaya Sanhita, 2023.
(d) With intent to cause injury to B, A institutes a criminal proceeding against him, knowing that there is no just or lawful ground for such proceeding, and also falsely accuses B of having committed an offence, knowing that there is no just or lawful ground for such charge. A may be separately charged with, and convicted of, two offences under section 248 of the Bharatiya Nyaya Sanhita, 2023.
(e) A, with intent to cause injury to B, falsely accuses him of having committed an offence, knowing that there is no just or lawful ground for such charge. On the trial, A gives false evidence against B, intending thereby to cause B to be convicted of a capital offence. A may be separately charged with, and convicted of, offences under sections 230 and 248 of the Bharatiya Nyaya Sanhita, 2023.
(f) A, with six others, commits the offences of rioting, grievous hurt and assaulting a public servant endeavouring in the discharge of his duty as such to suppress the riot. A may be separately charged with, and convicted of, offences under sub-section (2) of section 117, sub-section (2) of section 191 and section 195 of the Bharatiya Nyaya Sanhita, 2023.
(g) A threatens B, C and D at the same time with injury to their persons with intent to cause alarm to them. A may be separately charged with, and convicted of, each of the three offences under sub-sections (2) and (3) of section 351 of the Bharatiya Nyaya Sanhita, 2023.
The separate charges referred to in illustrations (a) to (g), respectively, may be tried at the same time.
Illustrations to sub-section (3)
(h) A wrongfully strikes B with a cane. A may be separately charged with, and convicted of, offences under sub-section (2) of section 115 and section 131 of the Bharatiya Nyaya Sanhita, 2023.
(i) Several stolen sacks of corn are made over to A and B, who knew they are stolen property, for the purpose of concealing them. A and B thereupon voluntarily assist each other to conceal the sacks at the bottom of a grain-pit. A and B may be separately charged with, and convicted of, offences under sub-sections (2) and (5) of section 317 of the Bharatiya Nyaya Sanhita, 2023.
(j) A exposes her child with the knowledge that she is thereby likely to cause its death. The child dies in consequence of such exposure. A may be separately charged with, and convicted of, offences under sections 93 and 105 of the Bharatiya Nyaya Sanhita, 2023.
(k) A dishonestly uses a forged document as genuine evidence, in order to convict B, a public servant, of an offence under section 201 of the Bharatiya Nyaya Sanhita, 2023. A may be separately charged with, and convicted of, offences under section 233 and sub-section (2) of section 340 (read with section 337) of that Sanhita.
Illustration to sub-section (4)
(l) A commits robbery on B, and in doing so voluntarily causes hurt to him. A may be separately charged with, and convicted of, offences under sub-section (2) of section 115 and sub-sections (2) and (4) of section 309 of the Bharatiya Nyaya Sanhita, 2023.
Section 243, The Bharatiya Nagarik Suraksha Sanhita, 2023 (Act 46 of 2023).
Replaces a provision of the Code of Criminal Procedure
CRPC 220 Trial for more than one offence Text carried over almost unchanged 98%
Measured by comparing the text of the two provisions, not taken from an official correspondence table — there is no machine-readable one. See both texts side by side before relying on it.
Both regimes are live. The repealed enactment still governs what happened while it was in force. We never redirect one to the other.
Cross-references
Extracted from the operative text of the enactments themselves. Every destination below exists in our corpus.
This section refers to
- Bharatiya Nyaya Sanhita s. 9 Limit of punishment of offence made up of several offences
- Bharatiya Nyaya Sanhita s. 93 Exposure and abandonment of child under twelve years of age, by parent or person having care of it
- Bharatiya Nyaya Sanhita s. 105 Punishment for culpable homicide not amounting to murder
- Bharatiya Nyaya Sanhita s. 131 Punishment for assault or criminal force otherwise than on grave provocation
- Bharatiya Nyaya Sanhita s. 195 Assaulting or obstructing public servant when suppressing riot, etc
- Bharatiya Nyaya Sanhita s. 201 Public servant framing an incorrect document with intent to cause injury
- Bharatiya Nyaya Sanhita s. 230 Giving or fabricating false evidence with intent to procure conviction of capital offence
- Bharatiya Nyaya Sanhita s. 248 False charge of offence made with intent to injure
- Bharatiya Nyaya Sanhita s. 263 Resistance or obstruction to lawful apprehension of another person
- Bharatiya Nyaya Sanhita s. 309 Robbery
- Bharatiya Nyaya Sanhita s. 317 Stolen property
- Bharatiya Nyaya Sanhita s. 331 Punishment for house-trespass or house-breaking
- Bharatiya Nyaya Sanhita s. 337 Forgery of record of Court or of public register, etc
- Bharatiya Nyaya Sanhita s. 341 Making or possessing counterfeit seal, etc., with intent to commit forgery punishable under section 338
- Bharatiya Nyaya Sanhita s. 351 Criminal intimidation
- s. 64 Summons how served
- s. 115 Assistance in relation to orders of attachment or forfeiture of property
- s. 117 Seizure or attachment of property
- s. 121 Fine in lieu of forfeiture
- s. 191 Complainant and witnesses not to be required to accompany police officer and not to be subject to restraint
- s. 233 Procedure to be followed when there is a complaint case and police investigation in respect of same offence
- s. 235 Particulars as to time, place and person
- s. 242 Offences of same kind within year may be charged together
- s. 337 Person once convicted or acquitted not to be tried for same offence
- s. 340 Right of person against whom proceedings are instituted to be defended
Related judgements & precedents
These are some judgments that construed this section, and hold precedence value. They hold authority on how to read, interpret and use this section.
-
Essar Teleholdings LTD vs Regr. Gen. Delhi High Court
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
When offences are committed in one series of acts forming the same criminal transaction, a Special Judge appointed under Section 3 of the Prevention of Corruption Act has the express authority under Section 4(3) of the PC Act to take cognizance of and try offences under the Indian Penal Code (such as Sections 420 and 120-B) against an accused, notwithstanding that the same offences would ordinarily be triable by a Magistrate, provided that co-accused in the same transaction are charged with offences specified in Section 3 of the PC Act. The application of Sections 220 and 223 of the Criminal Procedure Code permits such consolidated trial of co-accused charged with different offences arising from the same transaction, and the splitting of such trials would be incongruous and impractical. The High Court's Administrative Order and the State's Notification appointing a Special Judge for the 2G Spectrum cases were constitutionally valid exercises of authority under Articles 233-234 and Section 194 of the CrPC respectively, and cannot be collaterally assailed as they were premised on the Supreme Court's valid directions under Articles 136 and 142 of the Constitution.
On this section: Permits trial for more than one offence if committed in one series of acts forming the same transaction. Court applied this to allow petitioners (charged with IPC offences) to be tried with co-accused (charged with PC Act offences) arising from same 2G Spectrum transaction.
-
Kaushik Chaterjee vs State of Haryana
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
The question of territorial jurisdiction in criminal proceedings is a question of fact that must be established through evidence and cannot be decided at the transfer petition stage. The trial court, not the Supreme Court, is the appropriate forum to decide jurisdictional issues after evidence is led on the place of commission of the offence and other relevant factors enumerated in Sections 177 to 184 of the Code of Criminal Procedure. Therefore, transfer petitions seeking transfer on the ground of lack of territorial jurisdiction must be dismissed, leaving it open to the parties to raise and have the trial court decide the jurisdictional issue during the trial.
On this section: Allows any Court competent to inquire into or try any of the offences to inquire into or try all of them.
-
Bridgestone India Pvt. LTD vs Inderpal Singh
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
After the promulgation of the Negotiable Instruments (Amendment) Second Ordinance, 2015, territorial jurisdiction for criminal proceedings under Section 138 of the Negotiable Instruments Act, 1881, is determined by the place where the cheque is delivered for collection (i.e., the branch of the bank where the payee or holder in due course maintains the account) or where it is presented for payment (i.e., the branch of the drawee bank where the drawer maintains the account), not by the place where the cheque is drawn. The amended Section 142(2), through the non-obstante clause in Section 142A(1), overrides prior judgments and the general jurisdiction principles under Section 177 of the Criminal Procedure Code, 1973, and applies retrospectively to cases pending before the amendment came into force.
On this section: Provision regarding consolidation of offences. Referenced in the context of when multiple offences are committed in a single transaction.
-
Bridgestone India PVT LTD vs Inderpal Singh
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
After the promulgation of the Negotiable Instruments (Amendment) Second Ordinance, 2015, territorial jurisdiction for prosecuting an offence under Section 138 of the Negotiable Instruments Act, 1881, lies in the court within whose local jurisdiction the branch of the bank where the payee or holder in due course maintains an account is situated (i.e., where the cheque is delivered for collection), not where the cheque is drawn or where the drawee bank is located. The amended Section 142(2) and Section 142A(1) override the Criminal Procedure Code, 1973, and prior judgments, including Dashrath Rupsingh Rathod's case, and apply retrospectively to pending cases.
On this section: Cited in the context of exceptions to the general jurisdictional rule when multiple offences are committed in a single transaction.
-
Loop Telecom LTD vs Regr. Gen. Delhi High Court
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
Where co-accused in the same criminal transaction are charged with offences under the Prevention of Corruption Act, 1988 as well as offences under the Indian Penal Code, a Special Judge appointed under Section 3 of the Prevention of Corruption Act has valid jurisdiction under Section 4(3) of the PC Act read with Section 220 and Section 223 of the Criminal Procedure Code, 1973 to take cognizance of and try all accused jointly, including those charged solely with IPC offences. The Administrative Order of the High Court nominating a Special Judge and the Government Notification appointing such Special Judge are constitutionally valid exercises of authority under Article 233 of the Constitution and Section 3(1) of the Prevention of Corruption Act. The establishment of a Special Court to exclusively try cases arising from the same FIR and the same criminal transaction does not violate the Criminal Procedure Code or deprive the accused of valuable legal rights.
On this section: Permits trial for more than one offence if offences are committed in one series of acts forming the same transaction by the same person. Court applied this to justify trying co-accused charged with different offences (PC Act vs. IPC) together.
-
Vikash Saraf vs Registrar General Delhi H. Ct.
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
When co-accused are charged in the same transaction with offences under the Prevention of Corruption Act 1988, a Special Judge appointed under Section 3 of that Act has jurisdiction under Section 4(3) to try other co-accused charged only with Indian Penal Code offences (Sections 120-B and 420 IPC) relating to the same transaction. The application of Sections 220 and 223 of the Criminal Procedure Code permits consolidated trial of multiple accused charged with different offences arising from the same transaction. An Administrative Order passed by the High Court and a Notification issued by the State Government appointing a Special Judge to try all cases arising from the 2G Spectrum scam, including IPC offences, is constitutionally and legally valid as it falls within the statutory framework of the PC Act and Criminal Procedure Code and does not violate Article 14 of the Constitution merely by affecting appeal rights when there is no threat to fair trial. Supreme Court orders directing establishment of a Special Court passed under Articles 136 and 142 of the Constitution are binding and cannot be indirectly assailed through collateral challenges to the Special Court's jurisdiction.
On this section: Permits trial for more than one offence if committed in same series of acts forming same transaction. Applied to justify consolidated trial of co-accused charged with PC Act offences and IPC offences arising from 2G Spectrum allocation transactions.
-
Deepak Chaudhary vs State Nct of Delhi
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
While dishonour of each cheque constitutes a distinct offence and separate cause of action, Sections 219 and 220 of the Criminal Procedure Code provide exceptions to the general rule requiring separate trials. However, Section 219 CrPC restricts joint trial of offences of the same kind to a maximum of three offences committed within 12 months. Therefore, in cases involving more than three cheque dishonours, the trial court must club a maximum of three complaint cases for joint trial in accordance with Section 219 CrPC, and the remaining cases must be tried separately or in groups of three. Legislative amendment is required to allow joint trial of more than three cheque dishonour cases.
On this section: Provides that if more than one offence is committed by the same person in one series of acts forming the same transaction, all such offences may be charged and tried at one trial; the court examined whether eight cheque dishonours form the same transaction
-
Gatrod Agro Bio-fuels Private Ltd.& ORS. vs Garg Distilleries Private Ltd.
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
Where multiple cheques are dishonoured and separate statutory notices are issued under Section 138 of the Negotiable Instruments Act for each cheque, each cheque dishonour constitutes a separate cause of action. Consequently, such cases cannot be consolidated into a single trial under Section 219 CrPC, which is an enabling provision permitting but not mandating consolidation. The critical factor is whether a single notice or separate notices were issued; separate notices create separate causes of action requiring separate trials.
On this section: Related provision on consolidation; cited by applicants' counsel but distinguished by court
-
Gatrod Agro Bio-fuels Private Ltd.& ORS. vs Garg Distilleries Private Ltd.
Decided under Code of Criminal Procedure 220, which this section replaces. The court did not have this Act before it.
Court's Decision & Legal Precedent
When separate statutory notices are issued under Section 138 of the Negotiable Instruments Act for dishonour of different cheques, each cheque dishonour constitutes a separate cause of action, and therefore separate trials are permissible and legally justified. Section 219 of the Code of Criminal Procedure is an enabling provision that permits but does not mandate consolidation of trials. The issuance of separate notices, even on the same day, creates distinct causes of action that can be tried separately without illegality.
On this section: Cited by applicants' counsel regarding consolidation of trials; court found it inapplicable to the facts
The holding above is the ratio decidendi as extracted from the judgment by eCourts India, reproduced unaltered — it is a rendering of the court's reasoning, not a substitute for its words. Read the order itself before relying on it.
Questions about Section 243
What have the courts held on Section 243 of the Bharatiya Nagarik Suraksha Sanhita?
Essar Teleholdings LTD vs Regr. Gen. Delhi High Court (01 Jul 2013) is the leading judgment on this section among those set out below, though it was decided under CRPC 220, which this section replaced -- the court never mentioned this Act: Permits trial for more than one offence if committed in one series of acts forming the same transaction. Court applied this to allow petitioners (charged with IPC offences) to be tried with co-accused (charged with PC Act offences) arising from same 2G Spectrum transaction. Another 8 judgments on this section are set out below, 6 of them from the Supreme Court. They run from 2013 to 2024.
How do I find court cases under Section 243 of the Bharatiya Nagarik Suraksha Sanhita?
In judgments and charge sheets this section is written several ways, and each form finds a different set of orders. These search the full text of every order eCourtsIndia holds, best matches first: BNSS 243, section 243 BNSS, section 243 of the Bharatiya Nagarik Suraksha Sanhita. People searching for it also type 243 bnss in crpc and bnss 230 243. Each opens the full list of orders on eCourtsIndia, where it can be narrowed by court, year and outcome. 9 reported judgments on this section are set out on this page, beginning with Essar Teleholdings LTD vs Regr. Gen. Delhi High Court (01 Jul 2013).
What should I read with Section 243 of the Bharatiya Nagarik Suraksha Sanhita, and has it changed?
Its own text turns on Bharatiya Nyaya Sanhita 9 (Limit of punishment of offence made up of several offences), Bharatiya Nyaya Sanhita 93 (Exposure and abandonment of child under twelve years of age, by parent or person having care of it), Bharatiya Nyaya Sanhita 105 (Punishment for culpable homicide not amounting to murder), Bharatiya Nyaya Sanhita 131 (Punishment for assault or criminal force otherwise than on grave provocation), and on 21 further provisions, so none of them can safely be read on its own. 3 other provisions in this corpus refer back to it. It carries forward CrPC 220 (Trial for more than one offence), so the judgments decided under that provision are the case law on this one.
When did Section 243 of the Bharatiya Nagarik Suraksha Sanhita come into force?
Section 243 of the Bharatiya Nagarik Suraksha Sanhita, cited as BNSS 243, came into force on 01 Jul 2024, having been enacted on 25 Dec 2023. It is in force as at the date shown on this page.
Other sections of this Act
- 359. Compounding of offences1355 words
- 187. Procedure when investigation cannot be completed in twenty-four hours1122 words
- 2. Definitions956 words
- 35. When police may arrest without warrant881 words
- 480. When bail may be taken in case of non-bailable offence823 words
- 401. Order to release on probation of good conduct or after admonition810 words
Source and method. Compiled from the enactments of Parliament and of the State legislatures as published on India Code, and republished together with commentary and other original matter under section 52(1)(q)(ii) of the Copyright Act, 1957. Structured, cross-referenced and maintained by eCourtsIndia. Text as in force on 14 Oct 2026. This page is not a substitute for legal advice.