JAMIA MILLIA ISLAMIA – A CENTRAL UNIVERSITY

Faculty of law (New Delhi)

Remedies in case of non-registration of the FIR

SUBMITTED BY:- SUBMITTED TO :-

GUNJAN SINGH KHOKHAR DR. Mohammad Asad Malik

4th YEAR Regular (8th SEM) ASSOCIATE PROFESSOR

ROLL-NO. 26 CRPC - 1

“PROJECT – WORK”
ACKNOWLEDGMENT

1
Writing a project is one of the most significant academic challenges we have ever faced. Though
this project has been presented by Gunjan Singh Khokhar but there are many people who
remained in veil, who gave their all support and helped me to complete this project.

First of all I’m very grateful to my subject teacher ‘Dr. Mohammad Asad Malik Sir’ that he
provided me with such an opportunity to present on the topic “Remedies in case of non-
registration of the FIR” and me in every way possible. Without the kind support of whom and
help the completion of the project was a herculean task for me.

I acknowledge my friends who gave their valuable and meticulous advice which was very useful
and could not be ignored in writing the project.

Objectives

The main objective of the project is to highlight the remedies in case of non-registration of the
FIR.

Index

2
Introduction ………………………………………………………………….. 4

The legislative provisions…………………………………………………….. 5

 First Information Report

 In which cases an FIR can be registered?

 Who can file an FIR?

 What is the procedure for registration of an FIR?

 Cognizable offence

Refusal to register FIR: legal or illegal? ......................................................... 9

Remedy of non-registration of FIR ………………………………………….. 9

 Statutory Remedy

 Judicial Remedy

 Lalita Kumari case

 Human Rights Commission

 Writ petition

 Youth Bar Association of India vs. Union of India

Consequences of non-registration of FIR …………………………………… 13

Conclusion …………………………………………………………………….. 15

References …………………………………………………………………….. 16

Introduction

3
The basic purpose of filing a FIR is to set criminal law into motion and not to state all the minute
details therein First Information Report is the initial step in a criminal case recorded by the police
and contains the basic knowledge of the crime committed, place of commission, time of
commission, who was the victim, etc. The definition for the First Information Report has been
provided in the Code of Criminal Procedure, 1973 by the virtue of Sec. 154, which lays down
that:

“Every information relating to the commission of a cognizable offence, if given orally to an

officer in charge of a police station, shall be reduced to writing by him or under his direction, and
be read Over to the informant; and every such information, whether given in writing or reduced
to writing as aforesaid, shall be signed by the person giving it, and the substance thereof shall be
entered in a book to be kept by such officer in such form as the State Government may prescribe
in this behalf.

“ Information given under sub-section (1) of Section 154 of Cr.P.C., is commonly known as the
First Information Report (FIR), though this term is not used in the Code….And as it’s nick name
suggests, it is the earliest and the first information of a cognizable offence recorded by an officer
in charge of a police station”   

It will be no surprise if you come across a crime in today’s world. Assume that a theft has taken
place at house or your boss has sexually harassed you, or you witnessed two persons kidnapping
a child. In all these situations, the first thought that would come to your mind would be going to
the police station and file a complaint.

Suppose that you go to the police station carrying all that distress with you and you request the
police officer to register your complaint but guess what, the officer denies to file your complaint
leaving you in despair. Now, what do you do? Do you have any alternative other than filing the
complaint in the police station? Does the law provide us with any remedy for such instances?
Whether such an act of a police officer legal or illegal? These are some of the most basic
questions that would hit one’s mind in such a situation and in this project I’m going to answer
them all.

4
The legislative provisions

First Information Report?

F.I.R. means a FIRST INFORMATION REPORT. It is generally a document in which all the
information about the commission of a crime is recorded. Police Officers receive and record the
information at the first point. Therefore, it is known as the First Information Report. A First
Information Report, as the name suggests, is the first document that is formulated in a criminal
proceeding. The contents of an FIR consist of the information regarding the commission of an
offence, which is provided to the police. The police begin the investigation of a specific crime on
the basis of the FIR registered for the same. Therefore, an FIR plays a crucial role with regards to
the procedure of criminal law. Still another person can also provide the information and file
F.I.R. on behalf of the aggrieved person. There is no restriction of filing F.I.R. in writing only
but also a verbal message in this regard can also work in this process.

Another option is sending a message through the telephone. There are separate areas allotted to
police stations, under which the police officers handle particular cases. So F.I.R. can be filed in
that police station, under whose jurisdiction the crime was committed. Jurisdiction refers to the
geographical area under which the offense was committed, and therefore, the police station of
that place will be the place where the F.I.R. will need to be filed. The F.I.R. should be filed with
the officer-in-charge of the police station. In case he is not available, the Assistant Sub Inspector
can also record the F.I.R.

In which cases an FIR can be registered?

Section 154(1) of the Code of Criminal Procedure, 1973 clearly points out that an FIR could be
registered only in case of cognizable offences. Cognizable offences refer to those offences where
the police are permitted to arrest the accused without a warrant. In such offences, the police can
Suo moto take the cognizance of the offence and it does not require any sanction from the court
in order to begin the investigation. On the other hand, non-cognizable offences are those in
which police cannot make a conviction without taking a prior assent from the court. Schedule I

5
of the Criminal Procedure Code clearly distinguishes as to which offences are cognizable and
which are not.

Cognizable offence

Cognizable offences are defined in subsection (c) of section (2) of Civil Procedure Code 1908,
These offences are those where a police officer can arrest a person without warrant, as per the
first schedule of the Criminal Procedure Code, 1973 and after arrest accused will be produced
before the magistrate and magistrate will examine the matter and he may require the police
officer to investigate the matter, cognizable offence are both bailable and non-bailable. These
offences are usually serious in nature for example- murder, rape, dowry death, kidnapping, theft,
criminal breach of trust, unnatural offences, rioting armed with deadly weapon, waging war
against the government of India.

As per Sec. 156(1), the police has the authority to investigate a case involving a cognizable
offence without prior permission of the Magistrate. Sec. 156(1) lays down that:

“Any officer in charge of a police station may, without the order of a Magistrate, investigate any
cognizable case which a Court having jurisdiction over the local area within the limits of such
station would have the power to inquire into or try under the provisions of Chapter XIII.”

Section 156 (2) further reads,

“No proceeding of a police officer in any such case shall at any stage be called in question on the
ground that the case was one which such officer was not empowered under this section to
investigate.”

The term ‘cognizance’ as such has not been defined in the Code. The word as such has no
esoteric or mystic significance in Criminal Law or procedure. In reference to Courts or judicial
process, it simply means when the Court ‘takes notice judicially.

6
Who can file an FIR?

Any person who is aware of the offense can register an F.I.R. he doesn’t need to be an aggrieved
person. Even a police officer can file an F.I.R. if he comes to know about any offense. The F.I.R.
can be submitted by -
1) The Aggrieved person.
2) The person who is aware of the facts of the crime.
3) The person who has seen the commitment of the offense.

With regards to the persons who have the authority to file an FIR for a specific offence, either
the victim himself/herself, or a friend or relative of the victim, or any other person who has the
knowledge that the crime has been committed can file an FIR. The person who informs the
police about the commission of the offence is called an informant.

FIR can be registered by a victim, a witness or someone else with knowledge of the crime. As
per the laws laid down under section 154 of the Cr.P.C., the complainant can give information
about the offence either in written or orally. In regard to who can file an FIR, the Apex Court of
India has observed that;

“Section 154 does not require that the Report must be given by a person who has personal
knowledge of the incident reported. The section speaks of information relating to the commission
of a cognizable offence given to an officer in charge of a police station”.

The police is obliged to read the FIR back to the complainant in case it is conversed to them
orally to prevent the possibility of any differences in the oral and the written versions. Further it
is the duty of the complainant to report to the police station in person in case he had given the
information on a telephone. 

Tohal Singh vs. State of Rajasthan

“if the telephonic message has been given to officer in charge of a police station ,the person
giving the message is an ascertained one or is capable of being ascertained the information has

7
been reduced to writing as required under S.154 of Cr.Pc and it is faithful record of such
information and the information discloses commission of a cognizable offence and is not cryptic
one or incomplete in essential details, it would constitute FIR”.

However in a case wherein though the police officer went to the scene hearing rumors but
recorded a statement at the police station, it was held that in circumstances of the case that
statement could be accepted as FIR. The police are required to give a copy of the FIR to the
complainant free of charge.

What is the procedure for registration of an FIR?

As per the sub-section (1) of Section-154 Cr.P.C. when an informant informs the officer-in-

charge of a police station about the commission of a cognizable offence, it is the duty of the said
officer to record the same in the book that has been prescribed to them by the State government
for this purpose. If the informant has provided the information in oral form, then the officer must
reduce it in written form or get it reduced in written form under his supervision. As soon as the
writing down is done, the content must be read to the informant and then get it signed by the
informant once he is satisfied by the same. 

After all these steps are over, then the substance would be entered under the daily diary register.
However, if the information has already been given in the form of a written complaint which is
signed by the informant, then the entry could be made in the daily diary register straight away. 

This section further provides that if an offence under section 326A, 326B, 354, 354A, 354B,
354C, 354D, 376, 376A, 376B, 376C, 376D, 376E or 509 of the Indian Penal Code, has been
alleged to have committed against a woman, and the said woman herself is the informant in the
case, such information is to be recorded by a female police officer.

Moreover, if the victim against whom any of the offences mentioned above has alleged to have
been committed, and due to which the victim has acquired either physical or mental disability
which could either be temporary or permanent, then the recording of the information must be
done at victim’s place or any other place as per victim’s convenience.

8
Furthermore, as per Section 154(2) Cr.P.C., the police officer is supposed to provide a copy of
FIR to the informant chargeless. 

Remedy of non-registration of FIR

Refusal to register FIR: legal or illegal?

Whether the officer-in-charge of the police station can deny registering an FIR in any
circumstance then the denial by the police officer to file an FIR is considered legal typically in
two scenarios, firstly, if the complaint is about an awfully trivial issue, or secondly, if that
particular police station does not have the territorial jurisdiction of that offence. 

With regards to the first situation, it is unusual for a cognizable offence to be a nugatory matter
so this condition would hardly apply here. However, the refusal to register FIR based on the
second ground is pretty common and the solution to which is the “Zero FIR”. The concept of a
Zero FIR is that if a person is unable to file an FIR in the police station with correct territorial
jurisdiction for a particular offence due to any reason, then he may file the same in any other
police station within his/her reach, and such police station would later transfer the report to the
police station which actually has the jurisdiction for that offence. However, if the police officer
refuses to lodge the report on some unexplainable grounds or even without giving any reason,
it’d definitely be considered illegal. Then the aggrieved would have to seek remedy for the same
as provided under the law, which has been discussed next.

Statutory Remedy

As per the Clause (3) of Section 154 of Cr.P.C., if a person is refused by an officer-in-charge of a

police station to register his report, then such person has an option to send the content of the
information of crime in written form to the concerned Superintendent of Police via post so that
the information could be recorded and investigated upon. 

If the SP is contended with regards to the disclosure of a cognizable offence based on such
information, then he would either examine the case by himself or command any other

9
subordinate police officer to do the same in accordance with the Code. Also, the investigating
officer would have the same powers as the officer-in-charge of the police station with respect to
the investigation. 

Judicial Remedy

If the remedy under section-154(3) Cr.P.C. doesn’t prove to be effective, then the informant is
advised to directly file a private complaint before the concerned Judicial Magistrate
under Section 156(3) r/w Section 190 of the Criminal Procedure Code. Under this, the said
Magistrate is empowered to take the cognizance of the case on receiving such a complaint and
direct the police to investigate the case.

Lalita Kumari case

The most crucial landmark judgement when it comes to matters relating to the registration of FIR
is the Lalita Kumari v. Govt. of UP & Ors. The Supreme Court in this judgement laid down eight
guidelines that are to be followed by the police till date. The essential question that arose in the
case of Lalita Kumari was, “whether it is binding for the police to lodge an FIR when it is
informed about the occurrence of an offence which is cognizable in nature. The Apex Court
affirmatively answered this question and ruled that it is obligatory for the police to lodge an FIR
on receiving information that discloses the commission of a cognizable offence. 

The Court further held that if it is clear that a cognizable offence has been committed, the police
is not required to do any kind of preliminary inquiry. It means that the preliminary inquiry is
valid merely to the extent of determining whether the offence committed is cognizable or not.
Furthermore, the Apex Court clearly mentioned the kind of cases in which the preliminary
inquiry could be conducted by the police, which are family disputes, commercial offences,
medical negligence cases, corruption cases and cases with abnormal delay. Also, the Court
ordered that the preliminary inquiry must be started within 7 days of receiving the information of
offence.

10
1. Registration of FIR is mandatory under Section 154 of the Code, if the information
discloses commission of a cognizable offence and no preliminary inquiry is permissible
in such a situation.
2. If the information received does not disclose a cognizable offence but indicates the
necessity for an inquiry, a preliminary inquiry may be conducted only to ascertain
whether cognizable offence is disclosed or not.
3. If the inquiry discloses the commission of a cognizable offence, the FIR must be
registered. In cases where preliminary inquiry ends in closing the complaint, a copy of
the entry of such closure must be supplied to the first informant forthwith and not later
than one week. It must disclose reasons in brief for closing the complaint and not
proceeding further.
4. The police officer cannot avoid his duty of registering offence if cognizable offence is
disclosed. Action must be taken against erring officers who do not register the FIR if
information received by him discloses a cognizable offence.
5. The scope of preliminary inquiry is not to verify the veracity or otherwise of the
information received but only to ascertain whether the information reveals any
cognizable offence.
6. As to what type and in which cases preliminary inquiry is to be conducted will depend on
the facts and circumstances of each case. The category of cases in which preliminary
inquiry may be made are as under:

a) Matrimonial disputes/ family disputes.

b) Commercial offences

c) Medical negligence cases

d) Corruption cases

e) Cases where there is abnormal delay/laches in initiating criminal prosecution, for

example, over 3 months delay in reporting the matter without satisfactorily explaining the

11
 reasons for delay. The aforesaid are only illustrations and not exhaustive of all conditions
which may warrant preliminary inquiry.

7. While ensuring and protecting the rights of the accused and the complainant, a
preliminary inquiry should be made time bound and in any case it should not exceed 7
days. The fact of such delay and the causes of it must be reflected in the General Diary
entry. Since the General Diary/Station Diary/Daily Diary is the record of all information
received in a police station, we direct that all information relating to cognizable offences,
whether resulting in registration of FIR or leading to an inquiry, must be mandatorily and
meticulously reflected in the said Diary and the decision to conduct a preliminary inquiry
must also be reflected.

Human Rights Commission

A complaint can register with the State Human Rights Commission (SHRC) or the National
Human Rights Commission (NHRC) in case police didn’t register F.I.R. The NHRC provides a
facility to record and monitor the progress of the complaint online to the injured. The complaint
can be filed by filling your details, victim’s details, and incident’s details, violation of human
rights or negligence in the prevention of such violations, by a public servant in the complaint
registration form of the NHRC. Complaints can be made anytime by calling on the mobile
number of the commission.

Writ petition
Any person can file a writ petition in High Court under the provision of Section 482 of the
Criminal Procedure Code, 1973.

“Youth Bar Association of India vs. Union of India

In this case a writ petition preferred under article 32 of Constitution of India. The petitioner
youth Bar Association had prayed for issue of writ in the nature of Mandamus, directing UOI
and States to upload each and every FIR (first information report) registered in all the police
stations within the territory of India on the official website of Police of all states, as early as
possible, preferably within 24 hours from the time of registration of the FIR.

12
 The Supreme Court observed that- An accused is entitled to get a copy of the FIR at an
early stage than as prescribed under section 207 of the CrPC 1973. The accused may file
an application with a certain amount of fee prescribed by State Government to either
officer-in-charge of police station o superintendent of police to obtain a certified copy of
FIR within 24 hours. The accused may file an application with certain fee as prescribed
by the State Government before the concerned Magistrate or Special Judge to whom the
FIR has been forwarded and it will be provided within 2 working days.
 The copies of the FIR, unless the offence is sensitive in nature like sexual offences
pertaining to insurgence terrorism and of that category, offences under POCSO Act 2012
and such other offences should be upload on the police website.
 The decision not to upload the copy of the FIR on the website shall not be taken by an
officer below the rank of Dy.SP or any person holding equivalent post.
 If FIR is refused to be given because of sensitivity of the case, one can approach
Superintendent of police or Commissioner of police in metropolitan area. It will be
forwarded to committee of 3 police officials and decision will be given within 3 working
days as to whether a copy of the FIR can be granted or not.
 The Supreme Court directive regarding uploading the First information report on the
website of state police was a step to wholesome reform in the criminal proceedings’
apparatus. It aimed at promoting prompt action, transparency and curb arbitrariness. It
primarily safeguarded the interests of accused persons. The accused who may come to
know that he figured in a FIR, but has no idea of the allegations which form its basis. The
apex court’s judgement also benefited the victims of crime who have no means of getting
to know whether their complaint had been brought on record or not. The Indian police
department is known for dubious record of suppressing crime. Viewed in this perspective
the court’s prescription makes it difficult for station house officers to ignore crime, a
common practice adopted with a view to helping an offender or to dress police statistics
up so that they conceal a slightest rise in crime.”

13
Consequences of non-registration of FIR

The police officers who are at default regarding the refusal of registration of FIR in case of
cognizable cases may face several consequences owing to their inaction. If no action is taken by
the concerned authorities even after the aggrieved had gone for all the above-mentioned statutory
as well as judicial remedies then he may opt for the following actions.

The aggrieved person may file a writ petition in the respective High Court for the issuing of Writ
of Mandamus against the delinquent police officers, and then the Court would direct them to
come up with the reasoning as to why they did not lodge the report.

Another alternative that the aggrieved person could go for is to file a Writ Petition in the
respective High Court to seek compensation if such non-lodging of the report has caused the
person deprivation of his right to life and personal liberty as guaranteed by Article 21 of our
Constitution.

Additionally, the criminal law of our country also deals with this deplorable practise which is
carried out quite ordinarily these days. Section 166A of the Indian Penal Code lays down
punishment for a public servant who fails to record information. Specifically, sub-section (3) of
the section provides that failure on the part of a public servant to register any information u/s
154(1) of the Cr.P.C. with relation to the offences u/s 326A, 326B, 354, 354B, 370, 370A, 376,
376A, 376AB, 376B, 376C, 376D, 376DA, 376DB, 376E or 509 of the IPC, would attract this
section and the said public servant shall be punished with rigorous imprisonment for a term
which must not be less than 6 months but may extend to 2 years, and he shall also be liable to
fine.

Lallan Chaudhary v. State of Bihar

Supreme court held that the mandate of Section 154 is manifestly clear that if any information
disclosing a cognizable offense is laid before an officer in charge of a police station, such police
officer has no other option but to register the case on the basis of such information. The Supreme
court bench also observed that genuineness or credibility of the information is not considered to
be a condition precedent for registration of a case.

14
Bhajanlal v. State of Haryana
Supreme Court observed in this case that the legal mandate enshrined in Section 154(1) is that
every information relating to the commission of a “cognizable offense” if given orally or in
writing to “an officer in charge of a police station” (within the meaning of Section 2(o) of the
Code) and signed by the informant should be entered in a book to be kept by such officer in such
form as the State Government may prescribe which kind is commonly called as “First
Information Report” and which act of entering the information in the said form is known as
registration of a crime or a case.

Kathiravan vs. State

It is quite obvious that the officer in-charge of the police station, on receipt of a complaint
(information) disclosing commission of a cognizable offence, is duty bound to register a case and
such officer cannot probe into the allegations to find out whether they are true or not before
registering a case. However, it does not mean that in no case the officer in-charge of the police
station can conduct a preliminary enquiry to make a decision as to whether a case can be
registered for being investigated upon in accordance with the provisions of Cr.P.C. But such
cases are only exceptions to the general rule. Such exception should not be generalized by the
police to say that the police do have a discretion either to register the case or to conduct a
preliminary enquiry to make a decision whether to register a case or not.

Emperor vs. Khwaja Nazir Ahmad1

The Privy Council spelt out the power of the investigation of the police, as follows : "In India as
has been shown there is a statutory right on the part of the police to investigate the circumstances
of an alleged cognizable crime without requiring any authority from the judicial authorities, and
it would, as their Lordships think, be an unfortunate result if it should be held possible to
interfere with those statutory rights by an exercise of the inherent jurisdiction of the Court."This
plenary power of the police to investigate a cognizable offence is, however, not unlimited. It is
subject to certain well recognised limitation. One of them, is pointed out by the Privy Council,
1
AIR (32) 1945 PC 18

15
thus : "if no cognizable offence is disclosed, and still more if no offence of any kind is disclosed,
the police would have no authority to undertake an investigation. "

Ravi kumar v State of Punjab2

The Supreme Court stated “the first information report is a report giving information of the
commission of the cognizable crime which may be made by the complaint or by the complainant
or by any other person knowing about the commission of such offence. It is intended to set the
criminal law in motion. Any information relating to the commission of a cognizable offence is
required to be reduced to writing by the officer-in- charge of the police station which has to be
signed by the person giving it and the substance thereof is required to be entered into the book to
be kept by such officer in such form as the state government may prescribe in that behalf. The
registration of the FIR empowers the officer – in –charge of the police station to commence
investigation with respect to the crime reported to him. A copy of the FIR is required to be sent
forthwith to the Magistrate empowered to take cognizance of such offence.”

2
AIR 2005 SC 1929

16
Ravinder Kumar v. State of Punjab3

When there is criticism of the ground that FIR in a case was delayed the Court has to look at the
reason why there was such a delay. There can be a variety of genuine causes for FIR lodgment to
get delayed. Rural people might be ignorant of the need for informing the police of a crime
without any lapse of time. This kind of unconversantness is not too uncommon among urban
people also. They might not immediately think of going to the police station. Another possibility
is due to lack of adequate transport facilities for the informers to reach the police station. The
third, which is a quite common bearing, is that the kith and kin of deceased might take some
appreciable time to regain a certain level of tranquility of mind or sedativeness of temper for
moving to the police station for the purpose of furnishing the requisite information. Yet another
cause is, the persons who are supposed to give such information themselves could be physically
impaired that the police had to reach them on getting some nebulous information about the
incident.'' delay in its lodgment cannot be approved as a legal corollary. In any case, where there
is delay in making the FIR the court is to look at the causes are not attributable to any effort to
concoct a version no consequence shall be attached to the mere delay in lodging the FIR. In Tara
Singh V State of Punjab made the following observations: `It is well settled that the delay in
giving the FIR by itself cannot be ground to doubt the prosecution case.''

Ram Kumar Pande Vs. The State Of Madhya Pradesh4

The First Information Report is a previous statement which, strictly speaking, can be only used
to corroborate or contradict the maker of it.

Ram Jag And Others Vs. The State Of U.P.5

It is true that witnesses cannot be called upon to explain every hour's delay and a commonsense
view has to be taken in ascertaining whether the First Information Report was, lodged after an
undue delay so as to afford enough scope for manipulating evidence. Whether the delay is so
long as to throw a cloud of suspicion on the seeds of the prosecution must depend upon a variety

3
( SC) 2001 Crl.L.J.4242,
4
1975 AIR 1026, 1975 SCR (3) 519
5
1974 AIR 606, 1974 SCR (3) 9

17
of factors which would vary from case to case. Even a long delay in filing report of an
occurrence can be condoned if the witnesses on whose evidence the prosecution relies have no
motive for implicating the accused. On the other hand, prompt filing of the report is not an
unmistakable guarantee of the truthfulness of the version of the prosecution.

Conclusion

Whenever a cognizable offence is committed, the filing of an FIR is technically the first stage for
initiation of criminal proceedings, and hence the first step for seeking justice. It means when the
aggrieved person is denied to record his complaint, he is denied justice altogether. There is no
doubt that various remedies have been provided to aggrieved persons for the said circumstances
by the law, but all this running around to seek these remedies merely to get the complaint filed
sometimes delays the justice to such an extent that it feels denied. 

It is indisputable that this action of police officers is among the most atrocious practices of our
legal system because to report an offence that is committed to someone is one of the most basic
rights of that individual and ironically it is taken away by our protectors themselves. This
practice clearly leads to lawlessness and hence it must be put an end to.

The practice of refusal on the part of police officers to register FIR, no matter how barbaric it
seems, is pretty common. The reasons could be many, such as protecting the accused persons
who are powerful and have high contacts or harassing the poor victims, or irresponsible
behaviour of public servants, etc. Whatever may be the reason, it is the victim who suffers. The
victim who already has been through trauma due to the commission of an offence is put through
the whole agony once again when s/he is denied for lodging the report. 

18
BIBLIOGRAPHY

I. BOOKS:
 S.N. Misra, “the code of criminal procedure, 1973”, Central Law Publications, 19th ed., 2014.
 R.V.Kelkar, “criminal procedure”,eastern book company, 6th ed., 2014.
 DD Basu, Criminal Procedure Code, 379 (6th ed. 2017).

II. References

 https://indiankanoon.org/doc/10239019/
 https://indiankanoon.org/doc/445276/
 https://indiankanoon.org/doc/1569253/
 https://theprint.in/theprint-essential/whats-lalita-kumari-case-sc-verdict-judge-muralidhar-
held-up-as-model-for-delhi-police/372375/
 http://www.legalserviceindia.com/legal/article-1329-how-to-file-an-fir.html
 http://www.legalserviceindia.com/legal/article-4370-zero-fir.html
 https://www.latestlaws.com/bare-acts/central-acts-rules/ipc-section-166a-punishment-for-
non-recording-of-information-/
 http://www.legalserviceindia.com/legal/article-2897-what-is-an-fir-.html
 https://tripakshalitigation.com/non-registration-of-fir-by-police-and-its-consequences/
 https://www.lexology.com/library/detail.aspx?g=a750ca41-1b94-445e-aa91-
96c009bed6e5

19