Successive FIRs on identical facts by non-victims are impermissible and liable to be quashed.

The petitioner, Suresh Rathore, a former Member of the Legislative Assembly (MLA), was implicated in four First Information Reports (FIRs) filed under the Bhartiya Nyay Sanhita (BNS) 2023 and the Information Technology (Amendment) Act 2008.

The FIRs alleged that the petitioner and co-accused Urmila Sanavar uploaded vulgar and abusive videos/audio clips on social media to malign the reputation of Dushyant Kumar Gautam (National General Secretary of a political party) and others.

Specifically, the content sought to falsely link Gautam to the high-profile Ankita Bhandari murder case to gain political mileage.

Two FIRs were lodged by the victims themselves (Arti Gaur and Dushyant Kumar Gautam), while two others were filed by third parties in Haridwar alleging hurt to the "Ravidas Community" based on the same set of facts.

The petitioner sought quashing of all FIRs under Article 226.

1. Whether multiple FIRs containing identical allegations arising from the same transaction can be sustained against the same accused.

2. Whether the informants in FIR Nos. 356/2025 and 534/2025 qualify as "victims" under the law.

3. Whether the FIRs disclose cognizable offences warranting investigation despite being potentially politically motivated.

The court applied Section 2(wa) of the Cr.P.C. (corresponding to Section 2(4) of the BNSS 2023), which defines a "victim" as a person who has suffered loss or injury caused by the act of the accused.

It heavily relied on the precedent established in T.T. Antony v. State of Kerala (2001) 6 SCC 181, which prohibits the registration of a "second FIR" or fresh investigation into the same cognizable offence/incident.

The court cited M/s Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra regarding the statutory duty of police to investigate cognizable offences without premature judicial interference.

The court distinguished between the four FIRs based on the identity of the informants and the nature of the allegations.

Regarding FIR Nos. 356/2025 and 534/2025, the court found that the informants were neither victims nor affected parties as defined under Section 2(wa) of the Cr.P.C.

Since these FIRs contained the same allegations as the FIR subsequently filed by the actual victim (Gautam), they were deemed "successive FIRs" impermissible under the T.T. Antony doctrine.

Regarding FIR Nos. 0420/2025 and 0004/2026, the court noted they were filed by actual victims and prima facie disclosed cognizable offences.

The court reasoned that using social media to falsely project a public figure as a "sexual predator" involved in a heinous murder case (Ankita Bhandari) is a serious issue requiring thorough investigation into potential organized conspiracies and electronic evidence.

Conversely, the court dismissed Writ Petition Nos. 1801 of 2025 and 96 of 2026, vacating the interim protection granted to the petitioner, and held that FIR Nos. 0420/2025 and 0004/2026 must be investigated due to the gravity of the allegations.

The court further directed the D.G.P. and S.S.P. to assess and provide protection for the life and liberty of the informants Ms. Arti Gaur and Mr. Dushyant Kumar Gautam if required.