In Adil Noshir Mithaiwala v. State of Uttar Pradesh & Ors., decided on 13 November 2025, the Supreme Court of India held that criminal proceedings in India cannot be sustained when the same dispute has already been finally adjudicated and dismissed by courts in a foreign country. The appellants were accused under various IPC provisions based on a complaint filed by a UAE-based firm through its Power of Attorney holder. Notably, the complainant had earlier initiated both civil and criminal proceedings in the UAE on identical allegations, which were dismissed and had attained finality. The Court ruled that continuing proceedings in India amounted to abuse of process and violated the principle against double jeopardy. It also held that suppression of material facts regarding foreign proceedings was fatal to the complaint. Further, a PoA holder cannot depose on matters within the exclusive knowledge of the principal. Accordingly, the criminal proceedings were quashed.