Successive FIRs on identical facts are an abuse of process and cannot sustain parallel criminal proceedings.

A second FIR lodged by the same informant against the same accused on the same sale agreement and substantially identical allegations of fraud and forgery was an abuse of process and could not be sustained. Since the first FIR was already pending and the later FIR would expose the accused to multiple criminal proceedings for the same alleged offence, the Court held that such successive FIRs offend Articles 21 and 22 of the Constitution; the second FIR and all proceedings founded on it were quashed.

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Issues: Whether the second FIR, based on the same agreement, same allegations, same informant and same accused, was liable to be quashed as an abuse of process of law.

Analysis: Both FIRs were lodged by the same informant against the same accused and arose from the same sale agreement and substantially identical allegations of fraud and forgery. The second FIR was registered years after the first FIR, and the challenge to the first FIR was already pending. Permitting successive FIRs on the same facts would subject the accused to multiple criminal proceedings for the same alleged offence and would not withstand scrutiny under Articles 21 and 22 of the Constitution of India. The High Court failed to notice these material aspects.

Conclusion: The second FIR and all proceedings founded on it were liable to be quashed.

Final Conclusion: Successive FIRs on the same set of facts at the instance of the same informant cannot be sustained, and the impugned criminal proceedings were set aside.

Ratio Decidendi: A second FIR by the same informant against the same accused on the same facts and allegations is an abuse of process of law and is impermissible.

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