Trial for more than one offence
Section 220 of the Code of Criminal Procedure, 1973 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 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 Repealed by section 531 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (46 of 2023) with effect from 1 July 2024, but conduct before that date is still charged, tried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.
(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 212 or in sub-section (1) of section 219, 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 71 of the Indian Penal Code (45 of 1860).
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 sections 225 and 333 of the Indian Penal Code (45 of 1860).
(b) A commits house-breaking by day with intent to commit adultery, and commits, in the house so entered, adultery with B's wife. A may be separately charged with, and convicted of, offences under sections 454 and 497 of the Indian Penal Code (45 of 1860).
(c) A entices B, the wife of C, away from C, with intent to commit adultery with B, and then commits adultery with her. A may be separately charged with, and convicted of, offences under sections 498 and 497 of the Indian Penal Code (45 of 1860).
(d) 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 466 of the Indian Penal Code (45 of 1860). A may be separately charged with, and convicted of, the possession of each seal under section 473 of the Indian Penal Code (45 of 1860).
(e) 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 211 of the Indian Penal Code (45 of 1860).
(f) 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 211 and 194 of the Indian Penal Code (45 of 1860).
(g) 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 sections 147, 325 and 152 of the Indian Penal Code (45 of 1860).
(h) 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 section 506 of the Indian Penal Code (45 of 1860).
The separate charges referred to in Illustrations (a) to (h), respectively, may be tried at the same time.
Illustrations to sub-section (3)
(i) A wrongfully strikes B with a cane. A may be separately charged with and convicted of, offences under sections 352 and 323 of the Indian Penal Code (45 of 1860).
(j) 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 sections 411 and 414 of the Indian Penal Code (45 of 1860).
(k) 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 317 and 304 of the Indian Penal Code (45 of 1860).
(l) A dishonestly uses a forged document as genuine evidence, in order to convict B, a public servant, of an offence under section 167 of the Indian Penal Code. A may be separately charged with, and convicted of, offences under sections 471 (read with section 466) and 196 of that Code (45 of 1860).
Illustration to sub-section (4)
(m) 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 sections 323, 392 and 394 of the Indian Penal Code. (45 of 1860.)
Section 220, The Code of Criminal Procedure, 1973 (Act 2 of 1974).
Now in the Bharatiya Nagarik Suraksha Sanhita
BNSS 243 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
- s. 212 Particulars as to time, place and person
- s. 219 Three offences of same kind within year may be charged together
- s. 466 Defect or error not to make attachment unlawful
- s. 471 Exclusion of date on which Court is closed
- Indian Penal Code s. 71 Limit of punishment of offence made up of several offences
- Indian Penal Code s. 147 Punishment for rioting
- Indian Penal Code s. 152 Assaulting or obstructing public servant when suppressing riot, etc
- Indian Penal Code s. 167 Public servant framing an incorrect document with intent to cause injury
- Indian Penal Code s. 194 Giving or fabricating false evidence with intent to procure conviction of capital offence
- Indian Penal Code s. 211 False charge of offence made with intent to injure
- Indian Penal Code s. 225 Resistance or obstruction to lawful apprehension of another person
- Indian Penal Code s. 304 Punishment for culpable homicide not amounting to murder
- Indian Penal Code s. 317 Exposure and abandonment of child under twelve years, by parent or person having care of it
- Indian Penal Code s. 323 Punishment for voluntarily causing hurt
- Indian Penal Code s. 325 Punishment for voluntarily causing grievous hurt
- Indian Penal Code s. 333 Voluntarily causing grievous hurt to deter public servant from his duty
- Indian Penal Code s. 352 Punishment for assault or criminal force otherwise than on grave provocation
- Indian Penal Code s. 392 Punishment for robbery
- Indian Penal Code s. 394 Voluntarily causing hurt in committing robbery
- Indian Penal Code s. 411 Dishonestly receiving stolen property
- Indian Penal Code s. 414 Assisting in concealment of stolen property
- Indian Penal Code s. 454 Lurking house-trespass or house-breaking in order to commit offence punishable with imprisonment
- Indian Penal Code s. 466 Forgery of record of Court or of public register, etc
- Indian Penal Code s. 473 Making or possessing counterfeit seal, etc., with intent to commit forgery punishable otherwise
- Indian Penal Code s. 497 Adultery
- Indian Penal Code s. 498 Enticing or taking away or detaining with criminal intent a married woman
- Indian Penal Code s. 506 Punishment for criminal intimidation
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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Loop Telecom LTD vs Regr. Gen. Delhi High Court
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.
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Essar Teleholdings LTD vs Regr. Gen. Delhi High Court
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.
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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: Allows any Court competent to inquire into or try any of the offences to inquire into or try all of them.
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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. Referenced in the context of when multiple offences are 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.
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Vikash Saraf vs Registrar General Delhi H. Ct.
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.
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Deepak Chaudhary vs State Nct of Delhi
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
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Gatrod Agro Bio-fuels Private Ltd.& ORS. vs Garg Distilleries Private Ltd.
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
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Gatrod Agro Bio-fuels Private Ltd.& ORS. vs Garg Distilleries Private Ltd.
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.
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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… of Narmada Bai, the Court had observed that there was a situation which upon analysis of the allegations it appeared that abduction of Sohrabuddin and Kausarbi thei their subsequent murder as well as the murder of the witnesses are one series of facts and was connected together as to form the same transaction under Section 220 of the Code of Criminal Procedure and it was considered appropriate to transfer the investigation of the subsequent case also to CBI. 34. If we analyse the abovestated principles of law and apply the same to the facts of the present case, then the Court cannot rule out the possibility that all these acts and …
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… of Narmada Bai, the Court had observed that there was a situation which upon analysis of the allegations it appeared that abduction of Sohrabuddin and Kausarbi thei their subsequent murder as well as the murder of the witnesses are one series of facts and was connected together as to form the same transaction under Section 220 of the Code of Criminal Procedure and it was considered appropriate to transfer the investigation of the subsequent case also to CBI. 34. If we analyse the abovestated principles of law and apply the same to the facts of the present case, then the Court cannot rule out the possibility that all these acts and …
Questions about Section 220
What have the courts held on Section 220 of the Code of Criminal Procedure?
Loop Telecom LTD vs Regr. Gen. Delhi High Court (01 Jul 2013) is the leading judgment on this section among those set out below: 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. 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 220 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 220, section 220 CRPC, section 220 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. 9 reported judgments on this section are set out on this page, beginning with Loop Telecom LTD vs Regr. Gen. Delhi High Court (01 Jul 2013).
What should I read with Section 220 of the Code of Criminal Procedure, and has it changed?
Its own text turns on section 212 (Particulars as to time, place and person), section 219 (Three offences of same kind within year may be charged together), section 466 (Defect or error not to make attachment unlawful), section 471 (Exclusion of date on which Court is closed), and on 23 further provisions, so none of them can safely be read on its own. 3 other provisions in this corpus refer back to it. For anything done on or after 1 July 2024 the provision to read is BNSS 243 (Trial for more than one offence), which replaced it; conduct before that date is still charged, tried and appealed under this section.
When did Section 220 of the Code of Criminal Procedure come into force?
Section 220 of the Code of Criminal Procedure, cited as CRPC 220, 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
- 360. Order to release on probation of good conduct or after admonition804 words
- 2. Definitions799 words
- 198. Prosecution for offences against marriage774 words
- 145. Procedure where dispute concerning land or water is likely to causebreach of peace735 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.