Final exoneration in adjudication bars continued criminal prosecution on identical foreign exchange allegations.

Criminal complaints under foreign exchange laws could not be continued where the adjudicating authority had already recorded a complete exoneration on merits on the same facts and that order had attained finality. Although adjudication and criminal prosecution may proceed simultaneously and one does not ordinarily control the other, final exoneration in adjudication removes the factual basis for prosecution because criminal liability must still be proved to a stricter standard. On identical allegations, continuation of the complaints was therefore unjustified, and the complaints and consequential proceedings were liable to be quashed.

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Issues: Whether criminal complaints under the foreign exchange laws could continue after the petitioner had been exonerated on merits in the adjudication proceedings on the same set of facts.

Analysis: Adjudication proceedings and criminal prosecution may be launched simultaneously, and the outcome of one does not ordinarily control the other. However, where the adjudicating authority records a complete exoneration on merits on identical facts, and that order attains finality, the basis for continuing criminal prosecution disappears because the prosecution must still satisfy the stricter criminal standard of proof. In such a situation, continued prosecution on the same allegations would be unjustified.

Conclusion: The criminal complaints could not be sustained after the petitioner's exoneration on merits in adjudication, and the complaints and all consequential proceedings were liable to be quashed.

Ratio Decidendi: Where adjudication on the same facts ends in complete exoneration on merits and the order becomes final, criminal prosecution on those identical allegations cannot continue.

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