Place of trial for offences triable together
Section 184 of the Code of Criminal Procedure, 1973 deals with place of trial for offences triable together. Where- (a)the offences committed by any person are such that he may be charged with and tried at one trial for, each such offence by virtue of the provisions of section 219, section 220 or section 221,or (b) the offence of offences committed by several persons are such that they may be charged with The Act came into force on 01 Apr 1974. Repealed by section 531 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (46 of 2023) with effect from 1 July 2024, but conduct before that date is still charged, tried and appealed under it.
Where-
(a) the offences committed by any person are such that he may be charged with and tried at one trial for, each such offence by virtue of the provisions of section 219, section 220 or section 221,or
(b) the offence of offences committed by several persons are such that they may be charged with and tried together by virtue of the provisions of section 223,
the offences may be inquired into or tried by any Court competent to inquire into or try any of the offences.
Section 184, The Code of Criminal Procedure, 1973 (Act 2 of 1974).
Now in the Bharatiya Nagarik Suraksha Sanhita
BNSS 204 Place of trial for offences triable together Text carried over almost unchanged 100%
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 The repealed enactment still governs what happened while it was in force.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.
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.
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Kaushik Chaterjee vs State of Haryana
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: Provides that cases involving multiple offences of the same kind or multiple offences forming the same transaction may be inquired into or tried by any Court competent to inquire into or try any of the offences.
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Bridgestone India Pvt. LTD vs Inderpal Singh
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 committed in a single transaction.
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Bridgestone India PVT LTD vs Inderpal Singh
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.
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.
Judgments citing this section
These may be obiter dicta or a precedent, for you to study. These are the judgments where this section is quoted.
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… against the drawer of the cheque only before the Court within whose jurisdiction the dishonour takes place except in situations where the offence of dishonour of the cheque punishable under Section 138 is committed along with other offences in a single transaction within the meaning of Section 220(1) read with Section 184 of the Code of Criminal Procedure or is covered by the provisions of Section 182(1) read with Sections 184 and 220 thereof." 4. In order to resolve the concerns regarding the said judgment, the President of India promulgated an Ordinance, called Negotiable Instruments (Amendment) Ordinance, 2015. The said …
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… against the drawer of the cheque only before the Court within whose jurisdiction the dishonour takes place except in situations where the offence of dishonour of the cheque punishable under Section 138 is committed along with other offences in a single transaction within the meaning of Section 220(1) read with Section 184 of the Code of Criminal Procedure or is covered by the provisions of Section 182(1) read with Sections 184 and 220 thereof." 4. In order to resolve the concerns regarding the said judgment, the President of India promulgated an Ordinance, called Negotiable Instruments (Amendment) Ordinance, 2015. The said …
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… against the drawer of the cheque only before the Court within whose jurisdiction the dishonour takes place except in situations where the offence of dishonour of the cheque punishable under Section 138 is committed along with other offences in a single transaction within the meaning of Section 220(1) read with Section 184 of the Code of Criminal Procedure or is covered by the provisions of Section 182(1) read with Sections 184 and 220 thereof." 4. In order to resolve the concerns regarding the said judgment, the President of India promulgated an Ordinance, called Negotiable Instruments (Amendment) Ordinance, 2015. The said …
Questions about Section 184
What have the courts held on Section 184 of the Code of Criminal Procedure?
Kaushik Chaterjee vs State of Haryana (30 Sep 2020) is the leading judgment on this section among those set out below: Provides that cases involving multiple offences of the same kind or multiple offences forming the same transaction may be inquired into or tried by any Court competent to inquire into or try any of the offences. Another 2 judgments on this section are set out below, all of them from the Supreme Court. They run from 2015 to 2020.
How do I find court cases under Section 184 of the Code of Criminal Procedure?
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: CRPC 184, section 184 CRPC, section 184 of the Code of Criminal Procedure. Each opens the full list of orders on eCourtsIndia, where it can be narrowed by court, year and outcome. 3 reported judgments on this section are set out on this page, beginning with Kaushik Chaterjee vs State of Haryana (30 Sep 2020).
What should I read with Section 184 of the Code of Criminal Procedure, and has it changed?
Its own text turns on section 219 (Three offences of same kind within year may be charged together), section 220 (Trial for more than one offence), section 221 (Where it is doubtful what offence has been committed), section 223 (What persons may be charged jointly), so none of them can safely be read on its own. For anything done on or after 1 July 2024 the provision to read is BNSS 204 (Place of trial for offences triable together), which replaced it; conduct before that date is still charged, tried and appealed under this section.
When did Section 184 of the Code of Criminal Procedure come into force?
Section 184 of the Code of Criminal Procedure, cited as CRPC 184, came into force on 01 Apr 1974, having been enacted on 25 Jan 1974. It is no longer in force.
Other sections of this Act
- 320. Compounding of offences1554 words
- 167. Procedure when investigation cannot be completed in twenty four hours1005 words
- 220. Trial for more than one offence962 words
- 360. Order to release on probation of good conduct or after admonition804 words
- 2. Definitions799 words
- 198. Prosecution for offences against marriage774 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. Recovered from the consolidated text published by India Code (item 330a1099-77ad-4a2e-b22a-769b33398f9e). This page is not a substitute for legal advice.