Second FIR doctrine bars successive complaints for the same incident of arson and rioting; later proceedings quashed.

Successive FIRs cannot be maintained for the same cognizable occurrence or same transaction. Where the complaints concerned one incident of arson and rioting within the same compound on the same date, with closely connected premises, a common fire brigade response, and substantial identity in the allegations and persons implicated, the later FIRs were treated as impermissible second FIRs. The Court held that the mere fact that different occupants or portions of the premises were involved did not create separate incidents. The later FIRs and all proceedings arising from them were quashed, and the earliest FIR was left to continue as the governing complaint.

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Issues: Whether multiple FIRs could be maintained for the same occurrence of arson and rioting within one compound, and whether the subsequent FIRs and proceedings were liable to be quashed as impermissible second FIRs.

Analysis: The complaints disclosed a single incident in the same compound, occurring on the same date, involving closely connected premises and the same fire brigade response. The materials, including the site plan and charge-sheets, showed substantial identity in the allegations, the occurrence, and the persons implicated. Applying the settled principle that there cannot be successive FIRs for the same cognizable offence or the same transaction, the Court held that the later FIRs were not separate incidents merely because different occupants or portions of the same premises were involved. The proper course was to treat the later material, if any, as part of the first FIR and to proceed within that framework.

Conclusion: The later FIRs and all proceedings arising from them were quashed, while the earliest FIR was kept alive for further action.

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