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Searching Case Laws & Precedent on Legal Query.....!
Analysing the retrieved Case Laws
Scanned Judgements…!
Multiple Cause of Actions in FIRs - It is permissible to register separate FIRs on different causes of action, even if they relate to the same incident or involve the same parties, provided the facts and allegations are distinct. The courts recognize that each incident or set of allegations can warrant a separate FIR, especially when they involve different facts, offences, or persons ["MAHEJBIN SAKIRHUSSAIN SAIYED- disposed of as not pressed-order dated 10.09.2024. V/s STATE OF GUJARAT - Gujarat"], ["Amandeep Singh Saran VS State Of Delhi - Supreme Court"], ["YUVARAJ RAMAKRISHNA vs THE STATE OF TELANGANA - Telangana"].
Conditions for Multiple FIRs - The registration of more than one FIR is justified when the subsequent FIR is based on a different incident, involves different facts or persons, or alleges separate offences. The Supreme Court has clarified that if the second FIR pertains to a different set of allegations or a different incident, it is maintainable and not barred by the earlier FIR ["Mudavath Ramesh vs State of Telangana - Telangana"], ["E Raju @ M Raju vs The State of Telangana - Telangana"], ["YUVARAJ RAMAKRISHNA vs THE STATE OF TELANGANA - Telangana"].
Same Cause of Action and Quashing - The courts generally prohibit multiple FIRs on the same cause of action to prevent abuse of process. If the second FIR is merely a rephrasing or an attempt to include the same facts already covered in an earlier FIR, it may be quashed. However, if it involves a different incident or a broader scope, it can proceed ANTONY v. STATE OF KERALA, TT Antony ["Parul Budhraja vs State of U.P. - Allahabad"].
Civil vs. Criminal Proceedings - Civil disputes cannot automatically bar criminal proceedings, and separate FIRs can be registered for civilly related issues if criminal elements are involved. The existence of civil remedies does not preclude the registration of FIRs on criminal causes of action arising from the same facts ["NAGARAJU B H vs STATE OF KARNATAKA - Karnataka"].
Registration of Multiple FIRs in Different Jurisdictions - FIRs can be registered in different jurisdictions if the incidents are separate and the allegations are based on different facts or persons. Courts have upheld multiple FIRs where the scope of inquiry is different, and the incidents are distinct ["A. Saranika vs The Inspector of Police - Madras"], ["State (NCT) of Delhi VS Khimji Bhai Jadeja - Supreme Court"].
Analysis and Conclusion:A criminal complaint or FIR can be registered separately on different causes of action, especially when the facts, offences, or persons involved differ significantly. The key criterion is whether the subsequent FIR relates to a different incident or set of allegations. Courts tend to disallow multiple FIRs on the same cause of action to prevent abuse but permit multiple FIRs when the facts are separate and distinct. Proper judicial discretion is exercised to balance the interests of justice and prevent misuse of criminal proceedings ["MAHEJBIN SAKIRHUSSAIN SAIYED- disposed of as not pressed-order dated 10.09.2024. V/s STATE OF GUJARAT - Gujarat"], ["Amandeep Singh Saran VS State Of Delhi - Supreme Court"], ["YUVARAJ RAMAKRISHNA vs THE STATE OF TELANGANA - Telangana"].
In the realm of Indian criminal law, the registration of a First Information Report (FIR) is a crucial first step in initiating police investigation for cognizable offenses under the Code of Criminal Procedure (CrPC), 1973. But what happens when multiple complaints arise? Can a criminal complaint or FIR be registered separately on different causes of action? This question often arises in cases involving overlapping facts, repeated incidents, or disputes escalating from civil to criminal domains.
This blog post delves into the legal principles governing multiple FIRs, drawing from landmark judgments and recent case insights. We'll explore when separate registrations are permissible, when they're barred, and practical recommendations. Note: This is general information based on judicial precedents and not specific legal advice. Consult a qualified lawyer for your situation.
The foundational rule is straightforward: a criminal complaint or FIR can be registered separately on different causes of action only if the underlying facts or incidents are distinct and not part of the same transaction or occurrenceAMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697. Multiple FIRs are permissible when they pertain to different incidents or crimes, or when they involve different causes of action, provided they are not duplicates or mere variations of the same incident AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697.
As established in T.T. Antony v. State of Kerala, once an FIR is registered, subsequent information relating to the same incident cannot form the basis for a second FIR, unless it pertains to a different incident or cause AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697. Registering multiple FIRs on the same cause of action or same incident is generally impermissibleAMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697Central Bureau Of Investigation VS Surendra Patwa - 2025 4 Supreme 713. This prevents abuse of process, harassment, and multiplicity of proceedings.
In Lalita Kumari v. Govt. of Uttar Pradesh, the Supreme Court mandated FIR registration upon receipt of information about a cognizable offense, but emphasized that the key test is whether the information discloses a cognizable offense based on suspicion—not identical facts Central Bureau Of Investigation VS Surendra Patwa - 2025 4 Supreme 713.
Courts consistently quash successive FIRs based on the same facts or incident, viewing them as an abuse of process AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697. For instance:
The principle: If the answer is in the affirmative same incident, the second FIR is liable to be quashed. However, in case, the contrary is proved, where the version in the second FIR is different and they are in respect of the two different incidents/crimes, the second FIR is permissibleC. Ve. Shanmugam, B. A. B. L. VS State, rep. by Inspector of Police, Villupuram West Police Station, Villupuram Dist. (Crime No. 194 of 2022) - 2024 Supreme(Mad) 1315.
Conversely, FIRs relating to different incidents, events, or causes of action—even from the same broader context—can be registered separatelyAMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697. Examples include:
Different allegations by different persons: In State of Kerala v. ... (2018) 4 SCC 579, the Apex Court held that where the subsequent FIR was registered on different set of allegations by a different person, the said FIR is maintainableMudavath Ramesh vs The State of Telangana - 2025 Supreme(Online)(Tel) 56027E Raju M Raju vs State of Telangana - 2025 Supreme(Telangana) 476. The merits of each case must be considered to determine whether a subsequently registered FIR is a second FIR relating to the same incident or offence or is based upon distinct and different factsMudavath Ramesh vs The State of Telangana - 2025 Supreme(Online)(Tel) 56027.
Forgery and cheating as distinct offenses: Actions like deliberate fabrication of documents, manipulation of dates, and the fraudulent preparation of a forged agreement, which constitute distinct criminal offences independent of any civil cause of action allow separate FIRs Narendra Jain vs The State Of Madhya Pradesh - 2025 Supreme(Online)(MP) 11189.
Riots in different areas: Even arising from one event but involving different parties AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697.
New facts emerging post-initial FIR, leading to a different cause of action, may justify a subsequent FIR AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697.
Courts exercise inherent powers under Section 482 CrPC to quash duplicative FIRs, preventing harassment. In cases of doubt, they verify if facts relate to the same incidentAMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697.
However, territorial jurisdiction matters: Cause of action for quashing an FIR arises where it's registered, not everywhere part of the complaint arose Maria Ramesh VS State Rep. by The Assistant Commissioner of Police, Chennai - 2022 Supreme(Mad) 2655. Thus cause of action for lodging the criminal complaint is different from the cause of action for quashing the FIRMaria Ramesh VS State Rep. by The Assistant Commissioner of Police, Chennai - 2022 Supreme(Mad) 2655.
Civil-criminal overlap doesn't bar proceedings if criminal intent exists: When there is an element of criminal nature in the allegations leveled in the complaint/FIR, then certainly criminal law can be set in motion. Further, mere pendency of civil litigation... cannot be stayed or quashedHarmohinder Singh VS State of J&K - 2018 Supreme(J&K) 813.
Under special statutes like the Pre-Conception and Pre-Natal Diagnostic Techniques (PNDT) Act:- Police can register and investigate FIRs on Appropriate Authority complaints, but court cognizance requires their complaint Dhamayanthi Rajkumar VS State Rep. , by Inspector of Police, Salem - 2022 Supreme(Mad) 573Aparna Singhal VS State of Haryana - 2022 Supreme(P&H) 38. FIR for the offence committed under the Act can be registered on the complaint of the Appropriate Authority and can be investigated by the Police; however, cognizance... on the basis of a complaint made by one of the persons mentioned in Section 28Aparna Singhal VS State of Haryana - 2022 Supreme(P&H) 38.
To navigate this:- Authorities: Verify if facts relate to the same incident or different causes before registering AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697.- Courts: Scrutinize subsequent FIRs; quash if duplicative to prevent abuse AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697.- Practitioners: Examine factual basis; argue distinct causes where applicable.- Complainants: Lodge comprehensive details in one FIR; use preliminary inquiry if needed.
Understanding these nuances ensures fair process. For personalized guidance, seek expert legal counsel.
References:- AMISH DEVGAN VS UNION OF INDIA - 2020 0 Supreme(SC) 697: Principles on multiple FIRs for different incidents.- Central Bureau Of Investigation VS Surendra Patwa - 2025 4 Supreme 713: FIR mandate and same-incident bar.- Additional cases as cited inline.
#MultipleFIRs, #CriminalLawIndia, #FIRRegistration
Code of Criminal Procedure, 1973 (hereinafter referred to as “Cr.P.C.”), the applicantd habr prayed to quash and set aside the complaint being FIR No.11204001210023 of 2021 registered with Mahila Police Station, Kheda, for the offences under Sections 498-A/ ... Applicant No.2 is sister in law and applicant No.3 is husband of applicant No.2 and they are residing seperately and therefore, question does not arise to attract the provisions of section 498-A. The alleged incident took place between 2013 to 2020, whereas, the #....
As regards the FIRs registered in the States having special enactments, the first FIR registered in the concerned State be treated as principal criminal case; and the remaining FIRs and criminal case in that State shall stand clubbed/merged with the principal FIR/criminal case ... Issue a Writ of Mandamus or such other appropriate Writ directing that no further FIRs be registered against the Petitioner by any Investigating agency premised on the sam....
Their actions reveal the deliberate fabrication of documents, manipulation of dates, and the fraudulent preparation of a forged agreement, which constitute distinct criminal offences independent of any civil cause of action. 11. ... Per contra, counsel appearing for respondent No. 2 submits that the present FIR, dated 18.10.2024, was registered on a complaint made by the respondent/Complainant based on acts of forgery, cheating, misrepresentation, and fraudulent conduct committed by th....
Thus, it is made out that the two complaints are based on two different incidents. The cause of action is entirely different in both the cases. ... The present F.I.R. is registered based on the complaint that petitioner No.1 has created an Instagram ID and has posted vulgar messages and nude photos of the de facto complainant, whereby third parties have started calling her and her family members. ... It is with the said set of allegations, the earlier complaint was lo....
Thus, it is made out that the two complaints are based on two different incidents. The cause of action is entirely different in both the cases. ... The present F.I.R. is registered based on the complaint that petitioner No.1 has created an Instagram ID and has posted vulgar messages and nude photos of the de facto complainant, whereby third parties have started calling her and her family members. ... It is with the said set of allegations, the earlier complaint was lo....
an earlier FIR already stands registered. ... State of Kerala, (2018) 4 SCC 579, the Apex Court held that where the subsequent FIR was registered on different set of allegations by a different person, the said FIR is maintainable. 30. In Jakir Hussain Kosangi vs. ... The merits of each case must be considered to determine whether a subsequently registered FIR is a second FIR relating to the same incident or offence....
(2018) 4 SCC 579 ], the Apex Court held that where the subsequent FIR was registered on different set of allegations by a different person, the said FIR is maintainable. 30. ... However, where the incident is separate; offences are similar or different, or even where the subsequent crime is of such magnitude that it does not fall within the ambit and scope of the FIR recorded first, then a second FIR could be registered. ... If the ....
He submitted that since Basanta Kumar Behera himself was a signatory to the earlier complaint which led to registration of FIR No.79 of 2016, he could not have lodged a fresh complaint on the same cause of action. ... to which an earlier FIR already stands registered. ... However, where the incident is separate; offences are similar or different, or even where the subsequent crime is of such magnitude that it does not fall within the ambit and scope of the F....
If the answer is in the affirmative, the second FIR is liable to be quashed. However, in case, the contrary is proved, where the version in the second FIR is different and they are in respect of the two different incidents/crimes, the second FIR is permissible. ... In the later complaint there is nothing about use of criminal force or criminal restraint or spread of infectious disease or public nuisance. The respondent police had ignored the earlier ....
(2018) 4 SCC 579 ], the Apex Court held that where the subsequent FIR was registered on different set of allegations by a different person, the said FIR is maintainable. ... The merits of each case must be considered to determine whether a subsequently registered FIR is a second FIR relating to the same incident or offence or is based upon distinct and different facts and whether its scope of inquiry is entirely different#....
Thus cause of action for lodging the criminal complaint is different from the cause of action for quashing the FIR. Even assuming that the said registration of FIR in New Delhi is malafide, the cause of action for filing this Writ Petition to quash the said FIR could arise only before the Hon'ble High Court of New Delhi and not at all places where part of cause for lodging the complaint may have arisen and where the FIR could have been registered and investigated and where the ensuing criminal case could have been tried.
In the circumstances, the questions as formulated in the reference are answered in the following manner, that:- 1. Whether FIR for the offences committed under this Act can be registered on the complaint of Appropriate Authority and can be investigated by the Police? 3. Whether no FIR can be lodged nor the offences can be investigated by the Police and only complaint by the Appropriate Authority directly to the Court lies? 2. Whether the report under Section 173 Cr.P.C. along with the complaint of an Appropriate Authority can be filed to the Court? (1) FIR for the....
In the circumstances, the questions as formulated in the reference are answered in the following manner, that :- 1. Whether FIR for the offences committed under this Act can be registered on the complaint of Appropriate Authority and can be investigated by the Police? (1)FIR for the offence committed under the Act can be registered on the complaint of the Appropriate Authority and can be investigated by the Police; however, cognizance of the same can be taken by the Court on the basis of a complaint made by one of the persons mentioned in Section 28 of the Act.#HL....
When there is an element of criminal nature in the allegations leveled in the complaint/FIR, then certainly criminal law can be set in motion. Further, mere pendency of civil litigation with regard to same subject matter or document, criminal proceedings cannot be stayed or quashed.
On the basis of the said complaint, a criminal case was registered.
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