Re-litigation under Article 226 barred where a fresh writ repeats the same factual dispute despite added constitutional challenge.

A fresh writ petition based on the same complaints and substantially the same reliefs was declined under Article 226 because earlier writ proceedings on the same factual foundation had already been disposed of and were under appeal. The addition of a constitutional challenge to the investigation rules did not change the real character of the relief sought, which remained directed to the same dispute. The Court treated the filing as re-litigation, emphasising that repeated petitions on the same matter create multiplicity of proceedings and waste judicial time. The petition was therefore not entertained and was dismissed with costs.

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Issues: Whether the writ petition, filed after an earlier writ petition on the same factual basis was already disposed of and challenged in appeal, should be entertained under Article 226 of the Constitution of India despite the additional constitutional challenge to the investigation rules.

Analysis: The petition sought substantially the same reliefs arising from the same complaints that had already been the subject of earlier writ proceedings. The introduction of a constitutional challenge to the rules did not alter the real nature of the relief, which remained directed to the same complaints. The filing was viewed as an attempt to obtain another hearing on the same matter, leading to unnecessary multiplicity of proceedings and wastage of judicial time. The Court therefore declined to exercise its extraordinary writ jurisdiction.

Conclusion: The writ petition was not entertained and was dismissed with costs.

Final Conclusion: Re-litigation of the same factual dispute in a fresh writ petition was treated as unwarranted, and the Court refused to exercise writ jurisdiction.

Ratio Decidendi: Where a party seeks substantially the same relief on the same factual foundation after earlier writ proceedings, the Court may refuse to exercise Article 226 jurisdiction to prevent abuse of process and multiplicity of litigation.

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