Lalita Kumari v. Government of Uttar Pradesh (2014) – Mandatory FIR Registration

The Lalita Kumari case was a landmark ruling that clarified one of the most debated issues in criminal procedure: Is the police obligated to register a First Information Report (FIR) whenever a cognizable offence is reported?

Prior to this case, there was ambiguity in practice. Often, police officers would delay or even refuse to register FIRs, citing the need for preliminary inquiry. This created roadblocks for victims of serious crimes like assault, kidnapping, or sexual offences. In Lalita Kumari, the Supreme Court decisively ruled that the registration of an FIR is mandatory when information about a cognizable offence is received.

The Court also made an important distinction. While FIR registration is mandatory, it allowed for a preliminary inquiry in limited categories of cases, such as matrimonial disputes, commercial offences, or medical negligence, where immediate registration might not be appropriate. This balanced approach ensured that police officers could prevent misuse of the process, while still safeguarding victims’ rights.

The judgment has since transformed criminal law practice. By holding police accountable for prompt FIR registration, it strengthened citizens’ access to justice. It also curbed the misuse of police discretion and gave victims greater confidence in the legal system.

At Mullick & Co. Advocates, we see Lalita Kumari as a vital step in ensuring accountability and fairness in the criminal justice system. The decision aligns with our belief that law should always prioritize access to justice while balancing procedural safeguards.