Upkar Singh vs Ved Prakash & Ors on 10 September, 2004
In Amitbhai Shah Vs. CBI, reported in (2013) Cri.L.J. 2313, it
has been reiterated that second FIR, if in the nature of cross complaint
or counter complaint is permissible, which is an exception carved out in
Upkar Singh's case (supra) to the effect that, when the second FIR
consists of alleged offences which are in the nature of cross-case/cross-
complaint or counter-complaint, such cross-complaint would be
permitted as a FIR.