Second FIR barred for the same transaction and allegations, and proceedings founded on it were quashed.

A second FIR based on the same transaction, allegations, occurrence, and sequence of events already covered by earlier FIRs was held impermissible. The later investigation largely re-used documents, statements, and material collected in the earlier investigations, so it did not disclose a distinct cognizable offence or justify a fresh investigation. The governing principle is that successive FIRs are barred for the same offence or same transaction, although connected offences discovered during the same investigation may be addressed through supplementary steps. On that basis, the second FIR and the proceedings founded on it were quashed in respect of the petitioner.

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Issues: Whether the second FIR and the charge-sheet arising from it were liable to be quashed as being based on the same transaction and same set of allegations already covered by earlier FIRs.

Analysis: The material showed that the later crime number did not disclose a distinct occurrence. The allegations, place of occurrence, conspiracy, and sequence of events were the same as those forming the basis of the earlier crimes. The later investigation was found to consist substantially of transfer of documents, statements, and other material already collected in the earlier investigations. In such a situation, the governing principle is that there can be no second FIR and no fresh investigation in respect of the same cognizable offence or the same transaction, though connected offences discovered in the course of the same investigation may be dealt with by appropriate supplementary steps. The constitutional protection against arbitrary criminal process and the settled limitation on successive FIRs justified interference under the inherent jurisdiction.

Conclusion: The second FIR was invalid and the proceedings founded upon it were quashed in so far as they related to the petitioner.

Ratio Decidendi: A second FIR is impermissible when it concerns the same cognizable offence or same transaction already under investigation, and proceedings founded on such a duplicate FIR may be quashed as an abuse of process.

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