96. A plain reading of Section 154 of the Cr.P.C. makes it clear that a police officer is not obliged to record every subsequent piece of information in the station diary as the first information. The expression “second FIR” is a misnomer, for the law does not recognize the registration of more than one First Information Report in respect of the same offence. Any action taken by the police on information received after the first report forms part of the investigation into the same offence. The investigating agency, in the discharge of its bounden duty, must inquire not only into the cognizable offence disclosed in the first report but also into all connected offences arising from the same transaction or occurrence.

98. This Court in T.T. Antony (supra), categorically held that any information furnished to the officer in charge of a police station after the commencement of investigation would constitute a statement covered by Section 162 of the Cr.P.C. No such information, subsequent to the first information, can be treated as an FIR under Section 154 of the Cr.P.C., for that would amount to a “second FIR,” which is impermissible in law. The scheme of the Cr.P.C only recognizes the first information about a cognizable offence as satisfying the requirements of Section 154 of the Cr.P.C. It was held therein that there can be no fresh investigation on receipt of subsequent information qua the same cognizable offence/same occurrence/incident. The Court, without a scintilla of doubt, was correct in holding that a case arising out of second FIR is a fit case for exercise of power under Section 482 of the Cr.P.C. and/or Article 226 of the Constitution.

102. Recently, in State of Rajasthan v. Surendra Singh Rathore, reported in 2025 SCC OnLine SC 358, Sanjay Karol, J., upon referring to the earlier decisions of this Court, laid down the principles regarding the permissibility of the registration of a second FIR. The relevant paragraphs have been reproduced hereinbelow:-

“9. From the above conspectus of judgments, inter alia, the following principles emerge regarding the permissibility of the registration of a second FIR:

9.1 When the second FIR is counter-complaint or presents a rival version of a set of facts, in reference to which an earlier FIR already stands registered.

9.2 When the ambit of the two FIRs is different even though they may arise from the same set of circumstances. 9.3 When investigation and/or other avenues reveal the earlier FIR or set of facts to be part of a larger conspiracy.

9.4 When investigation and/or persons related to the incident bring to the light hitherto unknown facts or circumstances.

9.5 Where the incident is separate; offences are similar or different.”

(Emphasis supplied)