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🚨 Principle: Multiplicity of Proceedings Not in Larger Public Interest
The Supreme Court has held that when multiple FIRs are lodged on the same cause of action, it leads to harassment of the accused and wastage of judicial time. Such multiplicity of proceedings is not in the larger public interest, so the Court has directed that all FIRs be clubbed and investigated together on a state-wise basis.
⚖️ Detailed Explanation
Background
Sometimes, when a single incident or publication (for example, a news report, a speech, a social media post) affects people in different states, multiple FIRs are filed across the country.
If each FIR is investigated separately, the accused faces parallel investigations and trials in different states, which is unfair and causes duplication.
Supreme Court’s Stand
The Court emphasized the right to fair investigation and trial under Article 21 of the Constitution (Right to Life & Liberty).
It observed that harassment through multiple FIRs violates personal liberty and clogs the judicial system.
Hence, for the sake of justice, FIRs arising out of the same cause of action must be clubbed.
Doctrine Applied:
“Sameness of cause of action” → If the gravamen (core allegation) in different FIRs is the same, they should not be allowed to run independently.
Exception: If new and distinct allegations are made in another FIR, it may be allowed to proceed separately.
Supreme Court’s Direction
Instead of transferring all FIRs to one state only, the Court ordered state-wise clubbing.
Meaning: If multiple FIRs are filed in one state, they should be clubbed and investigated together within that state.
This balances both the interest of the accused and the concern of complainants in different states.
📌 Important Case Laws
T.T. Antony v. State of Kerala (2001) 6 SCC 181
Laid down that after registration of the first FIR, a second FIR for the same incident is not permissible.
Any further complaint should be treated as a statement under Section 162 CrPC in the same FIR.
Arnab Ranjan Goswami v. Union of India (2020) 14 SCC 12
Multiple FIRs were filed in different states against Arnab Goswami for his TV debate comments.
The SC quashed all other FIRs and directed that only the first FIR would continue.
It stressed that multiple proceedings cause misuse of criminal law and violate Article 19(1)(a) (freedom of speech).
Amish Devgan v. Union of India (2021) 1 SCC 1
Several FIRs were lodged in different states for his remarks during a TV show.
SC held that all FIRs should be consolidated and transferred to one jurisdiction (Noida police).
Niharika Infrastructure v. State of Maharashtra (2021) 9 SCC 1
Reaffirmed the principle that parallel investigations for the same cause of action must be avoided to protect fairness.
📝 Conclusion
The Supreme Court has balanced the rights of the accused and the public interest by ruling that:
Multiplicity of FIRs on the same cause of action is against larger public interest.
All FIRs should be clubbed state-wise to prevent harassment.
This ensures speedy justice, reduces judicial burden, and safeguards liberty under Article 21.
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