Repeated prosecutions for distinct financial transactions arising from a single inquiry do not constitute double jeopardy.

The petitioner, a former Deputy Registrar of Co-operative Societies, was accused of irregularities in confirming auction sales of land belonging to defaulting farmers between 2006 and 2009.

Following an inquiry based on a collective complaint, the Special Police Establishment (Lokayukta) registered twenty-four separate FIRs against him under the IPC and the Prevention of Corruption Act.

The petitioner was convicted in three of these cases, with appeals currently pending.

He approached the High Court seeking to quash the remaining nineteen trials and two pending investigations, arguing that since the cases arose from the same transaction and inquiry, they were barred by the prohibition against double jeopardy.

1. Whether the continuation of multiple trials arising from a single inquiry report violates the protection against double jeopardy under the Constitution and the statutory bar in the CrPC.

2. Whether the court should exercise its power to quash or club trials that have reached an advanced stage.

The court applied Article 20(2) of the Constitution of India, which protects against being prosecuted and punished for the same offense more than once, and Section 300 of the CrPC (now relevant under the BNSS), which bars a second trial for the same offense or on the same facts involving identical ingredients.

It distinguished the precedent in T.P. Gopalakrishnan v. State of Kerala, which requires an identity of facts for the bar to operate.

The court also referenced T.T. Antony v. State of Kerala regarding the impermissibility of a second FIR for the same occurrence and Sections 447, 448, and 449 of the BNSS regarding the transfer of cases.

The court reasoned that for the bar of double jeopardy to apply, the subsequent trial must involve the "same offense" or identical ingredients.

In this instance, while the petitioner's role as a confirming authority was a common thread, each FIR represented a distinct transaction involving different auctions, specific defaulting agriculturists, and unique financial calculations.

Therefore, each case constituted a separate offense rather than a single continuous occurrence.

Furthermore, the court noted that the Supreme Court had already rejected a prayer for clubbing these cases due to the advanced stage of the trials; consequently, quashing them would be an impermissible indirect override of that higher court's observation.

The Court exercised its power under Section 447 of the BNSS to direct the Sessions Judge, Bhopal, to transfer all pending cases to a single Special Court. Each case must be decided separately on its own merits.

The writ petition was disposed of with these directions, and all interim orders were vacated.