2025 Supreme(Telangana) 476
IN THE HIGH COURT OF TELANGANA
K. LAKSHMAN, J.
E Raju M Raju - Appellant
Vs.
The State of Telangana - Respondent
Writ Petition Nos.1591 AND 2884 OF 2025, 35951, 36532 AND 36554 of 2024
Decided On : 21-04-2025
Advocate Appeared:
For the Appellant : M A K MUKHEED
For the Respondent: GP FOR HOME
The court held that multiple FIRs cannot be registered for the same incident under established legal principles, emphasizing prohibitions against successive registrations when based on identical claims.
Headnote:(A) Bharatiya Nyaya Sanhita, 2023 - Sections 61(2), 191(2), 121(1), 126(2), 324(4); Prevention of Damage to Public Property Act, 1984 - Section 3 - Writ petitions filed to quash registration of multiple FIRs concerning a single incident - Court ruled that multiple FIRs for the same incident are impermissible - Citing principles established in TT Antony v. State of Kerala and Akbaruddin Owaisi v. State of AP regarding the same transaction, the court held registration of FIRs 154 and 155 of 2024 by the Bomraspet Police Station unconstitutional due to the same incident and commonality of complainants. (Paras 6, 10, 39, 40, 44)
Facts of the case:
Several complainants lodged FIRs against the petitioners for the same incident that occurred on 11.11.2024 during a public hearing, and it was argued that registering multiple FIRs for identical allegations was unlawful.
Findings of Court:
The court found that the events leading to all three FIRs were interrelated and stemmed from the same incident, hence, registration of additional FIRs was oppressive and unfounded.
Issues: Whether the registration of multiple FIRs for the same incident and allegations violates legal principles?
Ratio Decidendi: The court emphasized that no FIR should be registered concerning sequel events or the same incident, aligning with past judgments dictating the need for single FIR registration regarding identical allegations.
Result: Writ petitions allowed; FIRs 154 and 155 quashed.
| Table of Content |
|---|
| 1. factual background of the writ petitions. (Para 2 , 3 , 4) |
| 2. arguments regarding registration of firs. (Para 5 , 6 , 7) |
| 3. details of the incidents and allegations. (Para 8 , 9 , 10 , 11) |
| 4. legal principles on multiple fir registrations. (Para 12 , 13 , 14) |
| 5. observations from prior case law on firs. (Para 15 , 16 , 17 , 18 , 19) |
| 6. principle confirmation in related judgments. (Para 20 , 21 , 22 , 23) |
| 7. conditions for permissible multiple firs. (Para 26 , 28 , 29) |
| 8. court observations on legal principles of fir registration. (Para 30) |
| 9. court's final order on quashing firs. (Para 39 , 44) |
| 10. final ruling quashing the additional firs. (Para 42) |
ORDER :
(K. LAKSHMAN, J.)
Heard Mr. M.A.K. Mukheed, Mr. T.V.Ramana Rao, Mr. Ramu Nallamothu, learned counsel for the petitioners and Mr.Aniketh Reddy, learned Asst. Govt. Pleader for Home, appearing for State.
2. These writ petitions are filed to declare the action of the respondent Nos.3 to 6 in registering FIR Nos. 154 and 155 of 2024 of P.S. Bomraspet pertaining to the same incident which is the subject matter of FIR No.153 of 2024 and consequently quash the proceedings in Cr.Nos.154 and 155 of 2024.
3. In the light of the same, it is apt to refer the relevant particulars of the writ petitions, petitioners, FIRs, date, time and place of the incident and offences registered, against the petitioners in all the aforesaid crimes and the same are extracted below:-
| WP No. | Petitioner/s ranking in Cr.Nos. | Name of the complainant & Designation | Place, date & time of the incident | Offences |
| 1591/ 2025 | A.35 in 153/24, A.18 in 154/24 and A.3 in 155/24 of P.S.Bomraspet | N.Srinivasa Reddy, Sub Divisional Police Officer, Vikarabad in FIR No.153, | Anjaneya Temple, Lagcherla 11.11.2024 12.20 PM | under Sections 61 (2) 191(2), 191(3) 132,109, 121(1), 126(2), 324 (4) read with 190 BNS, Section 3 of PDPPA |
| 2884/23 | P.1 is A.38 in FIR No.153, A.21 in FIR No.154 & A.15 in FIR No.155 of 2024, P.2 is A.47 in FIR No.153, A.10 in FIR No.154 & A.11 in FIR No.155 of 2024, P.3 is A.10 in FIR No.153, A.5 in FIR No.154 & A.7 in FIR No.155 of 2024, P.4 is A.47 in FIR No.153, A.10 in FIR No.154 & A. No.11 in FIR No.155 of 2024, P P .5 is A.36 in FIR No.153, A.19 in FIR No.154 & A.13 in FIR No 155 of 2024, P.6 is A.42 in FIR No.153, A.16 in FIR No.154 and spet and as such I am well acquainted with the facts of the case. | Karra Kishan, MRO, Dudyal in FIR No.154 | Hanuman Temple, Lagcherla 1.11.2024 Time not specifically mentioned | under Sections 191 (2), 191(3) 132,109, 121(1), 126(2), 324 (4) read with 190 BNS , Section 3 of PDPPA |
| D. Janaiah, DCRB,DSP Vikarabad, in FIR No.155 of 2024, | Cherllapuram Venkataiah’s residence, Lagcherla | under Sections 191(2), 191(3) 132,109, 121(1), 126(2), 324 (4) read with 190 BNS, Section 3 of PDPPA | ||
| 35951/24 | P.1 is A. No. 11 in FIR No. 153, A.6 in FIR No. 154 & A.No.9 in FIR No. 155 of 2024. P.2 is A.2 in FIR No. 153, A.6 in FIR No. 154 & A.No.8 in FIR No. 155 of 2024. | |||
P.3 is A. 13 in FIR No. 153, A.7 in FIR No. 154 & A.9 in FIR No. 155 of 2024. | ||||
| 36532/24 | P.1 is A.4 in FIR No. 153, A.12 in FIR No. 154 & A.1 in FIR No. 155 of 2024. P.2 is A.5in FIR No. 153, A.8 in FIR No. 154 & A.No.5 in FIR No. 155 of 2024. P.3 is A.8 in FIR No. 153, A.15 in FIR No. 154 & A.4 in FIR No. 155 of 2024. 36554/ 24 Sole petiti | |||
36554/24 | Sole petitioner, A.6 in FIR No. 153, A.13 in FIR No. 154 |
4. In all the writ petitions, the petitioners are residents of Bala Naik Thanda, Roti Banda Thanda, Pulicherla kunta Thanda and Lagcherla Village, Bomraspet Mandal, Vikarabad District. They are accused in the aforesaid three crimes. On the complaints lodged by the aforesaid complainants, the Police Bomraspet registered the aforesaid three crimes.
5. Learned counsel for the petitioners would contend that the date of incident, place of incident etc., are same. Basing on the same incident, the police cannot register the aforesaid three crimes against the petitioners herein. The allegations leveled against the petitioners herein are same. Therefore, registra