KARI CHOUDHARY vs MOST. SITA DEVI .

The Supreme Court addressed the issue of double jeopardy in a murder case where the mother-in-law of the deceased was initially the complainant but later became an accused. The Court held that the High Court's quashing of the criminal proceedings against her, based on the premise of double jeopardy under Sections 188 and 211 IPC, was erroneous. The Court emphasized that the principle of double jeopardy does not apply as the earlier proceedings were not concluded with a trial, thus allowing the prosecution to continue under Section 302 IPC read with Section 34 IPC.