Successive Section 482 petitions are barred for old grounds, and repeated challenges to the same criminal proceedings amount to abuse of process.

Successive petitions under Section 482 CrPC are not barred in every case, but a second petition cannot be used to revive grounds that were already available when the first petition was filed. The inherent jurisdiction is not meant for piecemeal challenges to the same criminal proceedings or to delay the process. Where the charge sheet and cognizance order existed before the first petition and no material change occurred thereafter, a later petition challenging those steps is not maintainable and amounts to abuse of process. The Court held that the second petition was rightly dismissed.

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Issues: Whether a second petition under Section 482 of the Code of Criminal Procedure, 1973 is maintainable on grounds that were available when the first petition under the same provision was filed.

Analysis: Successive petitions under Section 482 of the Code of Criminal Procedure, 1973 are not barred in every case, but they cannot be used to raise pleas that were already available at the time of the earlier petition. The inherent jurisdiction cannot be invoked to permit an accused to challenge the same proceedings in instalments and thereby delay the criminal process. Where the charge sheet and cognizance order were already in existence when the first petition was filed and no change of circumstances occurred thereafter, a later petition challenging those very steps is not maintainable. Such repeated invocation of Section 482 would amount to abuse of process.

Conclusion: The second petition was not maintainable and was rightly dismissed.

Ratio Decidendi: A subsequent petition under Section 482 of the Code of Criminal Procedure, 1973 is maintainable only when it is founded on materially changed circumstances or grounds not previously available; it cannot be used to raise piecemeal challenges to proceedings that were already assailable in the earlier petition.

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