Complete FIR Law Table (30 Landmark Judgments)
| No | Legal Issue | Case Law | Court | Principle / Ratio |
|---|---|---|---|---|
| 1 | Mandatory registration of FIR | Lalita Kumari v. Government of Uttar Pradesh | Supreme Court | Police must register FIR if cognizable offence is disclosed. |
| 2 | Preliminary inquiry before FIR | Lalita Kumari v. Government of Uttar Pradesh | Supreme Court | Limited preliminary inquiry allowed in special categories like matrimonial disputes, corruption etc. |
| 3 | Second FIR barred | T.T. Antony v. State of Kerala | Supreme Court | Second FIR for same incident and same offence is not permissible. |
| 4 | Counter FIR permissible | Upkar Singh v. Ved Prakash | Supreme Court | Opposite party can lodge a counter FIR regarding same incident. |
| 5 | Delay in FIR not fatal | State of Himachal Pradesh v. Gian Chand | Supreme Court | Delay must be explained; not automatically fatal to prosecution. |
| 6 | FIR not encyclopedia | State of Andhra Pradesh v. Punati Ramulu | Supreme Court | FIR need not contain all details of the offence. |
| 7 | FIR cannot be treated as substantive evidence | Hasib v. State of Bihar | Supreme Court | FIR can only corroborate or contradict maker. |
| 8 | Police can add sections later | Sureshkumar Taraji Marwadi v. State of Gujarat | Gujarat High Court | Investigating officer can add offences during investigation. |
| 9 | Deletion of offences allowed | Vinubhai Haribhai Malaviya v. State of Gujarat | Supreme Court | Investigation may modify sections based on evidence. |
| 10 | Further investigation allowed | Vinay Tyagi v. Irshad Ali | Supreme Court | Police may conduct further investigation even after charge sheet. |
| 11 | Magistrate can order further investigation | Vinubhai Haribhai Malaviya v. State of Gujarat | Supreme Court | Magistrate has power under Section 173(8) CrPC. |
| 12 | FIR against unknown persons valid | Ramesh Baburao Devaskar v. State of Maharashtra | Supreme Court | FIR may be lodged even if accused is not known. |
| 13 | Anonymous complaint cannot be FIR | State of Haryana v. Bhajan Lal | Supreme Court | Complaint must disclose cognizable offence. |
| 14 | Grounds for quashing FIR | State of Haryana v. Bhajan Lal | Supreme Court | Seven categories laid down for quashing criminal proceedings. |
| 15 | FIR must disclose cognizable offence | Ramesh Kumari v. State (NCT of Delhi) | Supreme Court | Police bound to register FIR if offence disclosed. |
| 16 | Magistrate power to order FIR | Sakiri Vasu v. State of Uttar Pradesh | Supreme Court | Magistrate can direct registration under Section 156(3). |
| 17 | Alternative remedy before High Court | Sakiri Vasu v. State of Uttar Pradesh | Supreme Court | Aggrieved person should approach Magistrate before High Court. |
| 18 | FIR cannot be quashed at investigation stage easily | Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra | Supreme Court | Courts should not interfere in investigation normally. |
| 19 | Arrest safeguards | D.K. Basu v. State of West Bengal | Supreme Court | Mandatory guidelines for arrest and detention. |
| 20 | Multiple FIRs for different offences allowed | Babubhai v. State of Gujarat | Supreme Court | Separate FIR possible if incidents are distinct. |
| 21 | FIR can be lodged by any person | A.R. Antulay v. Ramdas Sriniwas Nayak | Supreme Court | Anyone aware of offence can inform police. |
| 22 | FIR by accused possible | Nathi Lal v. State of Uttar Pradesh | Supreme Court | Cross cases should be tried together. |
| 23 | FIR is not proof of guilt | Damodar Prasad v. State of Maharashtra | Supreme Court | FIR only initiates investigation. |
| 24 | FIR must be read as whole | State of Karnataka v. M. Devendrappa | Supreme Court | FIR should not be dissected. |
| 25 | Telephonic message not always FIR | Patai v. State of Uttar Pradesh | Supreme Court | Cryptic message not treated as FIR. |
| 26 | Delay in lodging FIR | Thulia Kali v. State of Tamil Nadu | Supreme Court | Unexplained delay weakens prosecution. |
| 27 | FIR can be used for contradiction | Damodar Prasad v. State of Maharashtra | Supreme Court | Under Evidence Act provisions. |
| 28 | FIR not substantive evidence | Hasib v. State of Bihar | Supreme Court | Only corroborative value. |
| 29 | Police must record information faithfully | Lalita Kumari v. Government of Uttar Pradesh | Supreme Court | Police cannot refuse registration arbitrarily. |
| 30 | FIR quashing power | State of Haryana v. Bhajan Lal | Supreme Court | High Court power under Section 482 CrPC. |
🧠 Magistrate Viva Quick Memory (10 One-Line Rules)
1️⃣ FIR is only the starting point of investigation.
2️⃣ Police must register FIR if cognizable offence appears.
3️⃣ Second FIR for same incident is barred.
4️⃣ Counter FIR by opposite party is permissible.
5️⃣ FIR is not substantive evidence.
6️⃣ Police may add or delete offences during investigation.
7️⃣ Magistrate can order FIR registration under Section 156(3).
8️⃣ Further investigation can be conducted even after charge sheet.
9️⃣ High Court should rarely quash FIR during investigation.
🔟 Delay in FIR is not fatal if properly explained.
⚖ Practical Judicial Use in Court Orders
Magistrates often use this reasoning:
“It is well settled that the FIR is not an encyclopedia of the prosecution case and the investigation agency is empowered to add appropriate sections of law as the investigation progresses.”
Cases supporting this reasoning:
-
State of Andhra Pradesh v. Punati Ramulu
-
Sureshkumar Taraji Marwadi v. State of Gujarat