Supreme Court: Res Judicata Applies in Criminal Cases Too with Full Trial Findings

The Supreme Court has clarified that the principle of res judicata applies to criminal cases where the earlier proceedings concluded with merit-based findings after a full trial. 

In this case, the accused was convicted under Section 138 of the Negotiable Instruments Act (NI Act) for dishonouring a cheque. During the trial, the court found that the defence of payment through demand drafts was without merit. 

Later, the accused filed a separate FIR under Section 420 of the Indian Penal Code (IPC) on the same grounds.

Citing Pritam Singh, the Supreme Court quashed the FIR, stating that the earlier findings barred re-litigation of the same issue.