Madhya Pradesh High Court (Single Judge)

MCRC, 18921 of 2017, Judgment Date: Oct 11, 2018

Law laid down -

[1] After registration of the first FIR the subsequent FIR for offence committed in the course of same transaction or offence arising as a consequence of prior offence, is not permissible and the subsequent complaint in such cases applying the test of “sameness” and “consequence” can be treated as statement under Section 161(3) of the Cr.P.C. in the FIR already registered but if the subsequent complaint is in regard to same incident but filed as a counter complaint or it is for the same nature of offence against same accused persons lodged by different persons or containing the different allegations, then it is to be registered as separate FIR.  

[2] The scope of quashing the FIR at the stage of investigation is limited and if prima facie commission of offence is disclosed in the FIR, then investigation should be allowed to continue. 

Taranjeet Singh Hora & Anr. Vs. State of M.P.