One FIR is sufficient for a single incident unless a larger conspiracy is indicated, allowing for further investigation without additional registrations.

ORDER

14.08.2025 Heard Mr. B.D. Das, learned Senior Counsel assisted by Mr. D. Thaosen, learned counsel for the petitioners and Mr. M.P. Goswami, learned Additional Public Prosecutor for the respondent no. 1, State of Assam.

2. This criminal revision petition under Section 528 read with Section 438 of Bharatiya Nagarik Suraksha Sanhita [ BNSS ], 2023 is preferred by the petitioners seeking quashing of a First Information Report [FIR], lodged on 10.01.2025 and registered on 13.04.2025 as Umrangso Police Station Case no. 08/2025 for the offences under Sections 303[2]/106[1] of Bharatiya Nyaya Sanhita [BNS], 2023. The petitioners have also assailed an Order dated 20.03.2025 passed by the Court of learned Chief Judicial Magistrate, Dima Hasao in Criminal Misc. Case no. 01/2025.

3. Before adverting to the contentions raised on behalf of the petitioners, it is relevant to mention that an unfortunate incident had occurred at 3 Kilo area in and around Umrangso on 06.01.2025. The case papers indicate that the said incident had occurred from activities of mining carried out in that area and the process adopted for mining was rat-hole coal mining. The incident resulted in tragic loss of twenty persons who were engaged as labours in the activities of coal extraction illegally from the well-type pit hole and got trapped in the pit under water.

4. One Senior Manager, Technical from M/s Assam Mineral Development Corporation Limited [AMDCL], a Government of Assam Undertaking, lodged a First Information Report [FIR] on 06.01.2025 before the Officer In-Charge Umrangso Police Station reporting inter-alia about the unfortunate incident, which had occurred on 06.01.2025, mentioned above. In the FIR, it was reported that the concerned area, Kalamati is at a distance of one kilometre approx. from the AMDCL’s Garampani Coal Mine Block. In the FIR, the informant had reported that nos. of persons were trapped inside the well-type pit hole under water. The informant further reported that the type of mining which was being carried out was very dangerous and the activities were being undertaken without any kind of permission from the Directorate of Geology & Mining, Assam or any other competent authority. The informant requested the Police authorities to undertake operation to rescue the trapped labourers from the pit hole mine.

5. On receipt of the FIR, the Officer In-Charge, Umrangso Police Station registered a case, Umrangso Police Station Case no. 02/2025 for the offences under Sections 3[5]/105, BNS read with Section 21[1] of Mines, Mineral [Development and Regulation] Act, 1957 and investigation was carried out thereafter. It is stated that during the course of investigation, twelve persons suspected to be involved in the activities of illegal rat-hole coal mining, were arrested. Subsequently, those twelve arrested accused persons were allowed to go on bail by Order dated 27.02.2025 and other subsequent orders. It has further emerged that the Investigating Officer [I.O.] of the case, Umrangso Police Station Case no. 02/2025, after carrying out the investigation, submitted a charge-sheet for the offences under Sections 105/303[2]/61[2]/3[5] of BNS read with Section 3 of the Prevention of Damage to Public Property Act, 1984. It is, however, not known from the materials on record as to when such charge-sheet has been submitted and who has/have been charge-sheeted.

6. The genesis of the present lis is another FIR lodged by two informants [the respondent no. 2 and the respondent no. 3] before the Officer In-Charge, Umrangso Police Station on 10.01.2025 which ha