Monday, 24 March 2025

Supreme Court: Magistrate Can't Direct FIR Registration Under S.156(3) CrPC If Complainant Didn't Approach Police Before u/s 154(1) & 154(3)

We have already indicated that there has to be prior applications under Sections 154(1) and 154(3) while filing a petition under Section 156(3). Both the aspects should be clearly spelt out in the application and necessary documents to that effect shall be filed. The warrant for giving a direction that an application under Section 156(3) be supported by an affidavit is so that the person making the application should be conscious and also endeavour to see that no false affidavit is made. It is because once an affidavit is found to be false, he will be liable for prosecution in accordance with law. This will deter him to casually invoke the authority of the Magistrate under Section 156(3). That apart, we have already stated that the veracity of the same can also be verified by the learned Magistrate, regard being had to the nature of allegations of the case. We are compelled to say so as a number of cases pertaining to fiscal sphere, matrimonial dispute/family disputes, commercial offences, medical negligence cases, corruption cases and the cases where there is abnormal delay/laches in initiating criminal prosecution, as are illustrated in Lalita Kumari are being filed. That apart, the learned Magistrate would also be aware of the delay in lodging of the FIR."{Para 31}

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

ABHAY S. OKA; J., UJJAL BHUYAN; J.

CRIMINAL APPEAL NO.4313 OF 2024;

 RANJIT SINGH BATH & ANR Vs UNION TERRITORY CHANDIGARH & ANR.

Dated: March 06, 2025.

Heard the learned counsel appearing for the appellants and the learned senior

counsel appearing for the second respondent-complainant.

2. On the basis of a complaint filed by the second respondent invoking Section 156(3)

of the Code of Criminal Procedure, 1973 (for short, "the CRPC"), an order was passed by

the learned Judicial Magistrate on 14th June, 2017 directing the concerned Police Station

to register a First Information Report for the offences punishable under Section 420 and

120-B of the Indian Penal Code, 1860 (for short, "the IPC"). The order of the learned

Magistrate was challenged by filing a quashing petition before the High Court of Punjab

and Haryana at Chandigarh. The High Court has dismissed the quashing petition by the

impugned order.

3. The learned counsel appearing for the appellants relies upon a decision of this Court

in the case of Mrs. Priyanka Srivastava and Anr. v. State of U.P. & Ors.1 He invited out

attention to what is held in paragraph 27 of the said decision. He also relied upon a

decision of this Court in the case Babu Venkatesh & Ors. v. State of Karnataka & Anr2

which follows the decision in the case of Priyanka Srivastava1.

4. The learned senior counsel appearing for the second respondent states that though

there is no specific averment regarding compliance with the requirements of sub-Sections

(1) and (3) of Section 154 of the CRPC, in substance, the compliance has been made. He

pointed out that in paragraph 14 of the complaint, it is stated that a written complaint was

addressed to the Inspector General of Police, Chandigarh which was marked to the

Economic Offences Wing of Chandigarh Police for inquiry under order dated 29th January,

2014. He accepts that there is no specific averment that a recourse was taken to Section

154(3) of the CRPC.

5. We have carefully perused the decision of this Court in the case of Priyanka

Srivastava1

. This Court has noted that there was misuse of the provisions of subSection

(3) of Section 156. In paragraphs 30 and 31, this Court held thus:

"30. In our considered opinion, a stage has come in this country where Section 156(3) CrPC

applications are to be supported by an affidavit duly sworn by the applicant who seeks the

1 (2015) 6 SCC 287

2 (2022) 5 SCC 639

2

invocation of the jurisdiction of the Magistrate. That apart, in an appropriate case, the learned

Magistrate would be well advised to verify the truth and also can verify the veracity of the

allegations. This affidavit can make the applicant more responsible. We are compelled to say so

as such kind of applications are being filed in a routine manner without taking any responsibility

whatsoever only to harass certain persons. That apart, it becomes more disturbing and alarming

when one tries to pick up people who are passing orders under a statutory provision which can

be challenged under the framework of the said Act or under Article 226 of the Constitution of India.

But it cannot be done to take undue advantage in a criminal court as if somebody is determined

to settle the scores.

31. We have already indicated that there has to be prior applications under Sections 154(1) and 154(3) while filing a petition under Section 156(3). Both the aspects should be clearly spelt out in

the application and necessary documents to that effect shall be filed. The warrant for giving a direction that an application under Section 156(3) be supported by an affidavit is so that the person making the application should be conscious and also endeavour to see that no false affidavit is made. It is because once an affidavit is found to be false, he will be liable for prosecution in accordance with law. This will deter him to casually invoke the authority of the Magistrate under Section 156(3). That apart, we have already stated that the veracity of the same can also be verified by the learned Magistrate, regard being had to the nature of allegations of the case. We are compelled to say so as a number of cases pertaining to fiscal sphere, matrimonial dispute/family disputes, commercial offences, medical negligence cases, corruption cases and the cases where there is abnormal delay/laches in initiating criminal prosecution, as

are illustrated in Lalita Kumari are being filed. That apart, the learned Magistrate would also be

aware of the delay in lodging of the FIR."

(underlines supplied)

6. Section 154 of the CRPC reads thus:

"154. Information in cognizable cases.

(1) 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:

[Provided that if the information is given by the woman against whom an offence under section

326A, section 326B, section 354, section 354A, section 354B, section 354C, section 354D,

section 376, section 376A, section 376B, section 376C, section 376D, section 376E or section

509 of the Indian Penal Code (45 of 1860) is alleged to have been committed or attempted, then

such information shall be recorded, by a woman police officer or any woman officer: Provided

further that--

(a) in the event that the person against whom an offence under section 354, section 354A,

section 354B, section 354C, section 354D, section 376, 2[section 376A, section

376AB, section 376B, section 376C, section 376D, section 376DA, section 376DB], section 376E

or section 509 of the Indian Penal Code (45 of 1860) is alleged to have been committed or

attempted, is temporarily or permanently mentally or physically disabled, then such information

shall be recorded by a police officer, at the residence of the person seeking to report such offence

or at a convenient place of such person’s choice, in the presence of an interpreter or a special

educator, as the case may be;

(b) the recording of such information shall be video graphed;

(c) the police officer shall get the statement of the person recorded by a Judicial Magistrate

under clause (a) of sub-section (5A) of section 164 as soon as possible.] ;

3

(2) A copy of the information as recorded under sub-section (1) shall be given forthwith, free

of cost, to the informant. (3) Any person aggrieved by a refusal on the part of an officer in charge

of a police station to record the information referred to in sub-section (1) may send the substance

of such information, in writing and by post, to the Superintendent of Police concerned who, if

satisfied that such information discloses the commission of a cognizable offence, shall either

investigate the case himself or direct an investigation to be made by any police officer subordinate

to him, in the manner provided by this Code, and such officer shall have all the powers of an

officer in charge of the police station in relation to that offence."

7. The requirement of sub-Section (1) of Section 154 is that information regarding

commission of a cognizable offence has to be furnished to an officer In-charge of a Police

Station. In this case, obviously, the said compliance was not made. It is stated that the

Inspector General of Police forwarded a complaint to the Economic Offences Wing. SubSection (3) of Section 154 comes into picture only when after a complaint is submitted to

the Officer In-charge of Police Station or information is provided to the Officer In-charge

of Police Station regarding commission of a cognizable offence, the Officer In-charge

refuses or neglects to register First Information Report.

8. Sub-Sections (1) and (3) of Section 154 of the CRPC are the two remedies available

for setting the criminal law in motion. Therefore, this Court held that before a complainant

chooses to adopt a remedy under Section 156(3) of the CRPC, he must exhaust his

remedies under sub-Sections (1) and (3) of Section 154 of the CRPC and he must make

those averments in the complaint and produce the documents in support. However, in this

case, the second respondent did not exhaust the remedies. In this view of the matter, we

find that both the learned Magistrate and the High Court have completely ignored the

binding decision of this Court in the case of Priyanka Srivastava1

.

9. We, therefore, quash and set aside both the impugned orders and quash and set

aside all the further steps taken on the basis of order dated 14th June, 2017 passed by the

learned Judicial Magistrate.

10. We make it clear that we have made no adjudication on the allegations made by

the second respondent. The second respondent is free to take recourse to the remedies

under Section 154 of the CRPC in accordance with law.

11. Subject to what is observed above, the appeal is allowed.


Print Page

No comments:

Post a Comment