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Supreme Court of India· 28 April 2025

Under the Code of Criminal Procedure, 1973, must police register an FIR with no complainant?

K. P. Tamilmaran v. The State by Deputy Superintendent of Police
2025 INSC 576 · SPECIAL LEAVE PETITION (CRIMINAL) NO.1522 OF 2023
Coram: Sudhanshu Dhulia; Prashant Kumar Mishra
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Answer

Yes. Once the police receive any information sufficient to suspect that a cognizable offence has been committed, whether through an informant or otherwise, registration of the FIR is obligatory under Sections 154(1) and 157(1). The plea that nobody came forward to lodge a complaint is unsustainable where the officers already had information regarding the crime.

Headnote

Indian Evidence Act, 1872 - s. 154 - Code of Criminal Procedure, 1973 - ss. 154(1), 311 - Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 - s. 4 - Hostile witness - Registration of FIR - Victim compensation - Indian Evidence Act, 1872 - s. 154 - Hostile witness - Evidence not washed off the record - Held: Evidence of a witness cross-examined by the party calling him cannot be washed off the record altogether. The Court may act on the part it finds creditworthy where corroborated by other reliable evidence, as Section 154(2) now expressly provides. (¶26, 31) Code of Criminal Procedure, 1973 - s. 311 - Material witness - Second part mandatory - Held further: The second part of Section 311 casts a duty rather than a discretion, obliging the Court to summon or recall any person whose evidence appears essential to the just decision of the case. An eyewitness omitted from the charge-sheet may be so summoned. (¶47, 48) Code of Criminal Procedure, 1973 - ss. 154(1), 157(1) - Registration of FIR - No informant needed - Held further: Once the police have information of a cognizable offence, from an informant or otherwise, registration of the FIR is obligatory. That nobody came forward to lodge a complaint is no defence where the officers knew of the crime. (¶69) Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 - ss. 3(2)(i), 4 - Police officers - Victim compensation - Held further: Officers who withheld the FIR to save the culprits, and the officer who manufactured an extra-judicial confession falsely implicating members of a Scheduled Caste, were rightly convicted. Compensation awarded; appeals dismissed. (¶74, 75, 76)

In the Court's own words
Paragraph 69Reading of the above provision should not be misunderstood to mean that the police is empowered to register FIR only in cases where some informant comes forward and provides information regarding the commission of a cognizable offence to the police. Once the police gets information regarding the commission of a cognizable offence, whether it is through any informant/complainant or otherwise, police is empowered to register the case and proceed with the investigation. This becomes clear from the bare reading of Sections 156 and 157 of CrPC. Section 156(1) reads as under:
Acts & Sections
s.154 Indian Evidence Act, 1872s.155 Indian Evidence Act, 1872s.165 Indian Evidence Act, 1872s.311 Code of Criminal Procedure, 1973s.154(1) Code of Criminal Procedure, 1973s.157(1) Code of Criminal Procedure, 1973s.162 Code of Criminal Procedure, 1973s.217 Indian Penal Code, 1860s.218 Indian Penal Code, 1860s.3(2)(i) Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989s.4 Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989

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Also decided in this judgment
Under the Indian Evidence Act, 1872, is a hostile witness's evidence wholly discarded?When must a criminal court summon a material witness under Section 311 of the CrPC?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections