सं Samvidhan

Bharatiya Nagarik Suraksha Sanhita, 2023

Section 173

Information in cognizable cases

Why this exists

This provision descends from Section 154 of the old Criminal Procedure Code, which required police to register a First Information Report (FIR) for cognizable crimes. Courts had long struggled with police refusing to register complaints, delaying justice or protecting the powerful. The new additions—electronic reporting, disability safeguards, and a formal preliminary enquiry option—respond to modern needs: digital complaints, protection of vulnerable victims (especially in sexual offence cases), and a way to filter out false or frivolous complaints in the 3-7 year offence range without diluting the core duty to register genuine crimes.

How courts read it

The Supreme Court's Constitution Bench in Lalita Kumari v. Govt. of UP (2014) held that registering an FIR is mandatory once information discloses a cognizable offence, but permitted a limited preliminary enquiry in specific categories (like matrimonial disputes, commercial disputes, or long-delayed complaints) to check genuineness before registration. Sub-section (3) appears to codify this balance into law by allowing a formal 14-day preliminary enquiry for mid-range offences. Earlier cases under the old Section 154, including State of Haryana v. Bhajan Lal, also shaped how courts scrutinize FIRs for abuse of process.

Common misconceptions
  • Myth: Police can freely refuse to register any complaint if they think it's weak.
    Fact: For truly cognizable offences, registration is normally mandatory; the limited 14-day preliminary enquiry option only applies to offences punishable by 3-7 years, and even then requires senior officer approval.
  • Myth: You must go in person to file an FIR.
    Fact: The law now expressly allows reporting a cognizable offence through electronic communication, which must be signed within three days.
  • Myth: If police refuse to file your FIR, you have no options left.
    Fact: You can send a written complaint to the Superintendent of Police, and if that fails too, approach a Magistrate.