Second Complaint After Closure Report in First Complaint Can’t Be Maintained by Adding New Offence for Same Incident — Supreme Court

The Supreme Court held that once a first complaint in a criminal matter has culminated in a closure report, a subsequent private complaint by the same informant over the same incident — even if it adds a different offence — is not maintainable under Code of Criminal Procedure, 1973 (CrPC) Section 200. (Live Law) The Court quashed the second complaint, declaring filing such subsequent complaints an abuse of process of law when there is no new incident, and when the initial closure was accepted. (Live Law) This judgment safeguards against harassment of accused by repetitious litigation and ensures finality in investigation — enhancing procedural fairness and avoiding multiplicity of proceedings based on the same factual matrix.