In Brief
The appellants were charged under two FIRs: the first for offences under the Immoral Traffic (Prevention) Act, 1956 (operating a flesh trade) and the second for offences under Sections 419–420 IPC (furnishing false information about their identity to police during the first FIR's investigation). The appellants argued that the second FIR violated the constitutional prohibition on double jeopardy and that offences should have been investigated as continuations of the first FIR under Section 173(8) Cr.P.C., not as a separate FIR. The Supreme Court dismissed the appeal, holding that where two FIRs cover offences that are substantially distinct in nature and character—one relating to immoral trafficking and the other to cheating by false identity—the second FIR is sustainable. The Court distinguished the case from the broad prohibition on successive FIRs, which applies only where the gravamen of both charges is identical or forms part of the same transaction.
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