Second FIR doctrine: distinct transactions and offences can sustain later complaints, with inherent quashing powers used sparingly.

A subsequent complaint is not barred as a second FIR where it concerns distinct offences, different parties, and a separate transaction, because the bar applies only when the later information relates to the same occurrence or same cognizable offence. The text applies that principle to hold that allegations linked to the Ahmedabad branch were separate from earlier allegations concerning the Mumbai branch, so the later complaints were maintainable. It also states that inherent powers under Section 482 CrPC are to be used sparingly and, absent exceptional grounds, should not be invoked to quash proceedings. On the facts, no basis was shown for interference with the refusal to quash or the order declining bail.

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Issues: (i) whether the subsequent complaints and investigation were barred as a second FIR arising out of the same cognizable offence, same occurrence, or same transaction; (ii) whether interference was warranted with the High Court's refusal to exercise inherent powers and with the order declining bail.

Issue (i): whether the subsequent complaints and investigation were barred as a second FIR arising out of the same cognizable offence, same occurrence, or same transaction.

Analysis: The governing principle is that only the earliest information in respect of a cognizable offence answers Section 154 of the Code of Criminal Procedure, 1973, and a second FIR is impermissible where it concerns the same incident or transaction. On the facts, however, the later complaints related to distinct malfeasance and misfeasance, different parties, and offences connected with the Ahmedabad branch, whereas the earlier FIR concerned a separate set of allegations relating to the Mumbai branch. The two sets of allegations were therefore not part of the same occurrence or same transaction.

Conclusion: The subsequent complaints were not barred as a second FIR and were maintainable.

Issue (ii): whether interference was warranted with the High Court's refusal to exercise inherent powers and with the order declining bail.

Analysis: The power under Section 482 of the Code of Criminal Procedure, 1973 is to be used sparingly, and no exceptional ground was shown for disturbing the High Court's refusal to quash the proceedings. In the bail matter, the record did not establish any basis for appellate interference, and the refusal of bail was found justified on the facts.

Conclusion: No interference was warranted with either the refusal to exercise inherent powers or the order declining bail.

Final Conclusion: The petitions and appeals failed, the criminal proceedings were allowed to continue, and the bail refusal remained undisturbed.

Ratio Decidendi: A subsequent complaint is not barred when it relates to distinct offences arising from different transactions, and inherent jurisdiction will not be exercised to quash such proceedings absent exceptional circumstances.

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