Successive Section 482 petitions are not maintainable without a material change in circumstances or unavailable grounds.

The petitioner filed a third successive petition under Section 482 of the Cr.P.C. seeking to quash an FIR.

Initially, the petitioner filed Criminal Writ Petition No. 25 of 2026, which was withdrawn with liberty to raise contentions at the stage of framing charges.

Disregarding this liberty, the petitioner filed a second petition (Cr.MMO No. 402 of 2026), which was also withdrawn on 13.05.2026.

The petitioner subsequently filed the present (third) petition, claiming "changed circumstances" due to a new police complaint filed by his relatives against the victim’s family and the filing of a supplementary charge sheet.

1. Whether a subsequent petition to quash an FIR is maintainable under Section 482 of the Cr.P.C. when earlier petitions for the same relief were withdrawn without a substantial change in circumstances.

2. Whether the filing of a cross-complaint by the accused's relatives or the submission of a supplementary charge sheet containing previously awaited forensic reports constitutes a "change in circumstances".

The court relied on the principle that while there is no blanket bar on successive petitions under Section 482 Cr.P.C., they are only maintainable if there is a material change in facts or circumstances.

Following Bhisham Lal Verma v. State of U.P. (2023) and M.C. Ravikumar v. D.S. Velmurugan (2025), the court emphasized that a party must raise all available pleas at the first instance and cannot approach the court with "installment pleas".

Section 362 of the Cr.P.C. bars the High Court from reviewing its own judgment or final order except to correct clerical or arithmetical errors, and inherent powers cannot be used to bypass this statutory prohibition.

The court found the petitioner’s claim of "changed circumstances" meritless. It observed that the new complaint dated 19.05.2026 was merely a reiteration of previous allegations and did not introduce material facts unknown at the time of the earlier petitions.

Regarding the supplementary charge sheet, the court noted it merely contained the analysis results (FSL/Expert reports) that were already anticipated during the original filing; thus, it supplemented rather than changed the nature of the evidence.

The court reasoned that permitting the petitioner to file multiple petitions instead of following the Division Bench’s direction to argue at the stage of framing charges would constitute an abuse of process and an attempt to stall proceedings.

The court answered the issues in the negative, stating that filing successive petitions on grounds already available constitutes a "review in disguise," which is prohibited under Section 362 Cr.P.C.

The petition was dismissed.