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International Journal of
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VOL. 11, ISSUE 12 (2025)
An analytical study of multiple firs: Legal principles and judicial trends
Authors
Dr. RK Singh, Dr. Manu Sharma
Abstract

This research paper critically examines the complex issue of multiple First Information Reports (FIRs) lodged for the same offence. The study explores whether successive FIRs for the same offence are legally sustainable within the Indian criminal justice framework, particularly in light of constitutional and statutory protections, such as, Article 20 (2) (protection against double jeopardy) and Section 337 of BNSS, 2023 (corresponding Section 300 (1) of the Cr.P.C, 1973). The principle of “sameness of offence”—established by the Supreme Court—is central to this analysis, as it differentiates between a “rival version” (permissible) and an “improved version” (impermissible) of the same illegality.

Through doctrinal methodology and critical evaluation of landmark cases (e.g., T.T. Antony, Ram Lal Narang, Nupur Sharma, Arnab Goswami, Amish Devgan), this study identifies six permissible grounds for registering successive FIRs and discusses how the absence of statutory clarity exacerbates the issue. The increasing role of electronic media complicates jurisdictional boundaries and leads to a proliferation of FIRs, often filed in different parts of the Country, creating a chilling effect on free speech and overburdening judicial institutions.

The paper recommends that either the legislature amend the BNSS, 2023 to clearly restrict multiple FIRs for the same offence, or the Supreme Court lay down binding guidelines. Drawing from the U.S. model of a Judicial Panel on Multidistrict Litigation, the study argues for a centralized, high court-monitored mechanism to prevent abuse and ensure uniformity. Ultimately, the research calls for legal reform to strike a balance between victim rights, accused protection, and judicial efficiency.
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Pages:139-147
How to cite this article:
Dr. RK Singh, Dr. Manu Sharma "An analytical study of multiple firs: Legal principles and judicial trends". International Journal of Law, Vol 11, Issue 12, 2025, Pages 139-147
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