Comprehension
In view of various counter claims regarding registration or non-registration, what is necessary is only that the information given to the police must disclose the commission of a cognizable offence. In such a situation, registration of a FIR is mandatory. However, if no cognizable offence is made out in the information given, then the FIR need not be registered immediately and perhaps the police can conduct a sort of preliminary verification or inquiry for the limited purpose of ascertaining as to whether a cognizable offence has been committed. But, if the information given clearly mentions the commission of a cognizable offence, there is no other option but to register a FIR forthwith. Other considerations are not relevant at the stage of registration of FIR, such as, whether the information is falsely given, whether the information is genuine, whether the information is credible etc. These are the issues that have to be verified during the investigation of the FIR. At the stage of registration of a FIR, what is to be seen is merely whether the information given ex facie discloses the commission of a cognizable offence. If, after investigation, the information given is found to be false, there is always an option to prosecute the complainant for filing a false FIR.

[Excerpted from the judgment delivered by Sathasivam, C.J.I. in Lalita Kumari v. State of Uttar Pradesh, (2014) 2 SCC 1 (hereafter ‘Lalita Kumari’)]
Question: 1

In the concluding part of the judgment excerpted above, preliminary inquiries were permitted for which of the following class or classes of cases?

Show Hint

Preliminary inquiry is the exception, not the rule — it applies only to specific classes of cases listed in Lalita Kumari.
Updated On: Jul 8, 2026
  • Offences related to matrimonial disputes
  • Allegations of corruption against public officers
  • Where the information was received after substantial delay, such as more than three months after the alleged incident
  • All the above
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The Correct Option is D

Approach Solution - 1

Step 1: Reference to Lalita Kumari guidelines.
In Lalita Kumari v. State of Uttar Pradesh (2014), the Supreme Court listed situations where preliminary inquiry is permissible before registering an FIR. These include matrimonial disputes, corruption allegations, and cases with abnormal delay in reporting.
Step 2: Option-wise analysis.
(A) Correct — matrimonial disputes often require preliminary verification.
(B) Correct — corruption allegations also fall in permissible preliminary inquiry category.
(C) Correct — substantial delay in complaint justifies limited preliminary inquiry. 
Step 3: Conclusion.
All three match the Court’s permissible categories ⇒ \(\boxed{\text{(D)}}\).

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Approach Solution -2

In Lalita Kumari v. State of Uttar Pradesh, the Supreme Court held that registration of an FIR is mandatory the moment information discloses a cognizable offence, but it carved out a limited set of case categories where the police may conduct a preliminary inquiry first, only to check if the information actually discloses a cognizable offence, before deciding whether to register an FIR. This question asks which categories the Court listed.

  1. Offences related to matrimonial disputes: The Court specifically listed matrimonial or family disputes as a category where a quick preliminary check is allowed, since such complaints can sometimes be exaggerated or filed in the heat of a domestic conflict, and a short verification prevents misuse of the criminal process.
  2. Allegations of corruption against public officers: The Court also included corruption cases in the list, since verifying such allegations often needs some preliminary fact-finding before a formal criminal case is launched against a public servant.
  3. Where the information was received after substantial delay, such as more than three months after the alleged incident: The Court listed cases with an abnormal, unexplained delay of this kind as another category warranting a preliminary check, since a long gap between the incident and the complaint can itself raise doubts that deserve a quick look before registration.
  4. All the above: Since the Court's list covers matrimonial disputes, corruption allegations, and cases of substantial delay together, along with commercial offences and medical negligence cases, this option correctly captures that all three named categories are genuine parts of the Court's list.

The Court's list in Lalita Kumari is not limited to one category, it spans several categories where verification helps avoid registering an FIR on a bare or unclear complaint, and matrimonial disputes, corruption allegations, and delayed complaints are three of the categories the Court expressly named.

So the correct answer is All the above.

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Question: 2

In the recent judgment of the Supreme Court in Netaji Achyut Shinde (Patil) v. State of Maharashtra (2021), which principle relating to FIR did the Court reiterate?

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An FIR must disclose the commission of a cognizable offence — vague or cryptic calls don’t qualify.
Updated On: Jul 8, 2026
  • That a cryptic phone call, without complete details and information about the commission of a cognizable offence cannot always be treated as a F.I.R.
  • That non-reading-over of the recorded complaint by the police to the informant will vitiate the recording of the F.I.R.
  • That F.I.R.s are substantive pieces of evidence at the trial and can be duly proved to establish the facts in issue at a trial.
  • That F.I.R.s are necessarily hearsay statements and cannot be relied upon to prove the truth of the matters asserted therein.
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The Correct Option is A

Approach Solution - 1

Step 1: Legal principle on FIR validity.
The Court clarified that the essential element of an FIR is that it must ex facie disclose the commission of a cognizable offence. A cryptic or incomplete message does not fulfill this requirement.
Step 2: Eliminating other options.
(B) Incorrect — non-reading-over is not the principle reiterated in this case.
(C) Incorrect — FIRs are not substantive evidence except for limited purposes.
(D) Incorrect — FIRs are not inherently hearsay; they have evidentiary value under certain provisions. 
Step 3: Conclusion.
Only (A) matches the principle reiterated ⇒ \(\boxed{\text{(A)}}\).

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Approach Solution -2

This question asks which principle about FIRs the Supreme Court reiterated in Netaji Achyut Shinde (Patil) v. State of Maharashtra. The core requirement for something to count as an FIR is that it must, on its face, disclose the commission of a cognizable offence, and the four options test different, unrelated propositions about FIR law.

  1. That a cryptic phone call, without complete details and information about the commission of a cognizable offence cannot always be treated as a F.I.R.: This matches the settled position that a message which is vague, incomplete, or merely alerts the police to go to a spot, without disclosing the actual commission of a cognizable offence, does not by itself qualify as an FIR. The formal FIR is then the first statement that does disclose the offence with enough detail, recorded once the police reach the scene or the informant later gives a fuller account.
  2. That non-reading-over of the recorded complaint by the police to the informant will vitiate the recording of the F.I.R.: This describes a procedural safeguard under Section 154 CrPC about reading back the recorded complaint to the informant, but it is a separate issue from what makes a message cryptic or complete, and is not the principle this case reiterated.
  3. That F.I.R.s are substantive pieces of evidence at the trial and can be duly proved to establish the facts in issue at a trial: This misstates FIR law. An FIR is not substantive evidence of the facts stated in it, its evidentiary use is limited, mainly to corroborate or contradict the informant's testimony under the Evidence Act, not to prove the truth of what it contains.
  4. That F.I.R.s are necessarily hearsay statements and cannot be relied upon to prove the truth of the matters asserted therein: This overstates the position. FIRs are not treated as inherently worthless hearsay, they retain limited evidentiary value, for instance to corroborate or contradict a witness, or in narrow cases as a dying declaration or an admission, so calling them "necessarily" unusable hearsay is incorrect.

The principle actually reiterated in this case is about what counts as an FIR in the first place, namely that a bare, incomplete phone call missing the details of a cognizable offence does not automatically qualify.

So the correct answer is That a cryptic phone call, without complete details and information about the commission of a cognizable offence cannot always be treated as a F.I.R.

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Question: 3

A police officer, after receiving information about a cognizable offence, records it in the Station House Diary and begins investigation without registering a formal FIR. The FIR is registered only the next day. On which ground can the FIR be challenged?

Show Hint

The first version of facts given to the police about a cognizable offence is the FIR — later formal recordings are treated as investigation statements.
Updated On: Jul 8, 2026
  • That the police officer has not followed the mandatory procedure of sending a copy of the FIR to the jurisdictional magistrate upon registration.
  • That the statement recorded as the FIR is a hearsay statement made by the police officer himself and therefore cannot be admissible in evidence.
  • That the recorded FIR becomes a statement under Section 161, Code of Criminal Procedure, 1973, because the Station House Diary entry will be considered the FIR.
  • That the procedure set out in Section 190, Code of Criminal Procedure, 1973 has been violated by the police officer.
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The Correct Option is C

Approach Solution - 1

Step 1: FIR registration requirement.
As per Lalita Kumari, once information discloses a cognizable offence, FIR must be registered forthwith. Recording it in a Station House Diary without FIR registration is improper. 
Step 2: Legal consequence.
If the first recorded version is in the Station House Diary, it is treated as the FIR. Any subsequent formal FIR becomes a statement during investigation under Section 161 CrPC. 
Step 3: Conclusion.
This is exactly what option (C) states ⇒ \(\boxed{\text{(C)}}\).

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Approach Solution -2

This question presents a scenario where a police officer records information about a cognizable offence in the Station House Diary and starts investigating without registering a formal FIR, only registering one the next day. It asks on what ground this can be challenged, testing the legal consequence of failing to register an FIR at the very first point information disclosing a cognizable offence is received.

  1. That the police officer has not followed the mandatory procedure of sending a copy of the FIR to the jurisdictional magistrate upon registration: This concerns a separate obligation under Section 157 CrPC to forward a copy of the FIR to the magistrate, and nothing in the facts says this step was skipped, so it is not the ground raised by this scenario.
  2. That the statement recorded as the FIR is a hearsay statement made by the police officer himself and therefore cannot be admissible in evidence: This mischaracterises the problem. The issue here is not that the police officer's own account is hearsay, it is that a formal FIR was not registered at the earliest point information disclosing a cognizable offence came in, which is a registration defect, not an evidentiary hearsay problem.
  3. That the recorded FIR becomes a statement under Section 161, Code of Criminal Procedure, 1973, because the Station House Diary entry will be considered the FIR: This correctly captures the legal consequence. Since the police officer received information disclosing a cognizable offence and recorded it in the Station House Diary before beginning investigation, that diary entry is, in law, the real FIR. The document drawn up the next day and formally labelled "FIR" is then treated as a statement recorded during the course of investigation under Section 161, not as the FIR itself.
  4. That the procedure set out in Section 190, Code of Criminal Procedure, 1973 has been violated by the police officer: Section 190 concerns a magistrate's power to take cognizance of an offence, a stage that comes later and involves the magistrate, not the police officer's duty to register an FIR, so this is not the ground that fits the facts.

Because the police officer already had information disclosing a cognizable offence and noted it in the Station House Diary before starting the investigation, that first entry is what the law treats as the FIR, making the next day's formal document a mere Section 161 statement.

So the correct answer is That the recorded FIR becomes a statement under Section 161, Code of Criminal Procedure, 1973, because the Station House Diary entry will be considered the FIR.

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Question: 4

In Aghnoo Nagesia v. State of Bihar (1966), the accused registered an FIR against himself without prior accusation. How would such an FIR be treated?

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Under Section 25, any confession to police, even voluntarily made, is inadmissible against the accused.
Updated On: Jul 8, 2026
  • Violative of right against self-incrimination under Article 20(3) of the Constitution of India.
  • A statement that cannot be proved as a confession hit by Section 25, Indian Evidence Act, 1872.
  • A statement that can be used as substantive evidence against its maker, since there was no accusation against him at the time he made the statement.
  • A statement that can be retracted by the accused person at the time of trial, and thereafter the commission of the offence cannot be proved.
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The Correct Option is B

Approach Solution - 1

Step 1: Self-incriminatory FIR.
Section 25 of the Evidence Act bars the use of confessions made to a police officer as proof against the accused. An FIR lodged by the accused containing a confession is covered by this bar. 
Step 2: Why Article 20(3) not applicable here.
Article 20(3) protects against compelled self-incrimination. Here, the statement was voluntary; the bar arises from Section 25, not constitutional compulsion.
Step 3: Conclusion.
Thus, the FIR cannot be used to prove the confession ⇒ \(\boxed{\text{(B)}}\).

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Approach Solution -2

The question is about how the Supreme Court in Aghnoo Nagesia v. State of Bihar (1966) treated a first information report where the accused's own statement to the police disclosed his commission of the offence, given before any accusation had been levelled against him. Let us examine each option on its own footing.

  1. Option A: Article 20(3) protects a person from being compelled to be a witness against himself. The constitutional guarantee is triggered only where there is compulsion. In this case, the accused walked into the police station and volunteered the information; there was no compulsion by the investigating authorities. The bar on using the statement therefore does not flow from Article 20(3) at all, it flows from an ordinary rule of evidence law. This option misattributes the source of the protection.
  2. Option B: Section 25 of the Indian Evidence Act, 1872 provides that no confession made to a police officer shall be proved against a person accused of any offence. Where the informant's own report to the police, in substance, admits the commission of the offence, that report is a confession within the meaning of the Act, and it makes no difference that it was made before any formal accusation, since the moment the statement itself discloses guilt it becomes a confessional statement made to a police officer. Such a statement is therefore inadmissible as a confession under Section 25 and cannot be used to prove guilt against its maker.
  3. Option C: This option suggests the opposite result, that the statement becomes usable substantive evidence merely because no accusation preceded it. That reasoning would defeat the very purpose of Section 25, which exists precisely to prevent police-recorded admissions, however voluntarily given, from being used as proof of guilt. The absence of a prior accusation does not convert a confession into ordinary admissible evidence.
  4. Option D: The premise here, that the accused may retract the statement at trial and thereby defeat proof of the offence, misunderstands the true position. The statement is not inadmissible merely because it can later be retracted; it is inadmissible from the outset because it is a confession made to a police officer, barred by Section 25. Retraction is not the operative legal principle at play.

Testing each option against the statutory bar in Section 25 shows that only one option correctly identifies why the FIR cannot be used against the accused, it is barred as a confession to a police officer, not because of a constitutional compulsion requirement, a supposed absence-of-accusation exception, or a retraction rule.

Therefore, the correct answer is a statement that cannot be proved as a confession hit by Section 25, Indian Evidence Act, 1872.

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Question: 5

In Pakala Narayanaswami v. King Emperor (1939), the Privy Council held that a statement is a confession if:

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A confession need not be a verbatim admission of guilt — admitting all ingredients of the offence is enough.
Updated On: Jul 8, 2026
  • Admitted the commission of the offence in the terms of the offence.
  • Admitted the commission of the ingredients for the commission of the offence.
  • Either (A) or (B)
  • Both (A) and (B)
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The Correct Option is C

Approach Solution - 1

Step 1: Definition from Privy Council.
In Pakala Narayanaswami, a confession was defined broadly to include not only a direct admission of the offence but also an admission of all facts that constitute the offence.
Step 2: Applying to options.
(A) Correct — direct admission in offence terms is a confession.
(B) Correct — admission of ingredients constituting the offence is also a confession.
Thus, (C) “Either (A) or (B)” correctly covers both.
Step 3: Conclusion.
\(\boxed{\text{(C)}}\) is the answer.
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Approach Solution -2

The question asks for the precise standard laid down by the Privy Council in Pakala Narayanaswami v. King Emperor (1939) for when a statement qualifies as a confession. Let us look at what each option asserts.

  1. Option A: This option describes a statement that admits the offence in the very terms of the offence itself, for example, an accused stating that he committed the murder. Read alone, this option would confine confession only to a full, direct admission and would exclude a statement that admits every fact making up the offence without using the language of the offence itself. That is narrower than what the Privy Council actually said.
  2. Option B: This option describes a statement admitting all the facts that, taken together, constitute the offence, without necessarily using the language of an outright admission of guilt. Read alone, this too is only part of the Privy Council's formulation, since it omits the direct-admission branch captured in Option A.
  3. Option C: This option states that a confession exists if either the direct-admission branch (A) or the ingredients-admission branch (B) is satisfied. This mirrors the Privy Council's formulation precisely, a statement is a confession if it admits the offence in terms, or, failing that, if it admits substantially all the facts constituting the offence. Only one of these two routes needs to be satisfied for the statement to count as a confession.
  4. Option D: This option requires both the direct-admission branch and the ingredients-admission branch to be satisfied simultaneously before a statement is a confession. That would make the definition far stricter than the Privy Council intended, since the Court's language was deliberately disjunctive, not conjunctive.

Because the Privy Council's own words set up an alternative test, satisfying only one of the two conditions suffices, the option correctly capturing this disjunctive standard is the one that says either branch will do.

Therefore, the correct answer is Either (A) or (B).

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Question: 6

In the excerpt above, the Supreme Court refers to the standard of ex facie. Such a standard in law can be explained as:

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Ex facie = obvious at first glance — think “no microscope needed.”
Updated On: Jul 8, 2026
  • Refers to a standard where a document by its stated terms displays the sought fact.
  • Refers to a standard where a document by very simple perusal displays the sought fact.
  • Refers to a standard which calls for an application of mind by the finder of fact to infer a conclusion.
  • Refers to a standard which requires no consideration unless proved otherwise by the opposite side.
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The Correct Option is B

Approach Solution - 1

Step 1: Meaning of ex facie.
The term means “on the face of it” — something apparent without detailed investigation or inference. |
Step 2: Matching with the legal context.
In legal terms, ex facie refers to what is immediately obvious from a document or act upon straightforward reading, without the need for deeper analysis. 
Step 3: Option elimination.
(A) Incorrect — while close, “stated terms” may still require interpretation.
(B) Correct — “simple perusal” captures the immediate-obviousness aspect.
(C) Incorrect — this involves inference, contrary to ex facie meaning.
(D) Incorrect — unrelated to burden of proof considerations.
Step 4: Conclusion.
Thus, \(\boxed{\text{(B)}}\) is correct.

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Approach Solution -2

The question asks what the standard of ex facie means, as used by the Supreme Court in the excerpt. Let us test each option against the ordinary legal meaning of the Latin phrase, which translates to on the face of it.

  1. Option A: This option ties the standard to the stated terms of the document, that is, to its express recitals or wording. But a document's stated terms can still require the reader to interpret, cross-reference, or construe language before the sought fact emerges, which is a step beyond mere appearance. This option therefore captures something closer to textual interpretation than to the immediate, surface-level obviousness that ex facie denotes.
  2. Option B: This option ties the standard to what appears on very simple perusal, that is, what any reader would see immediately on looking at the document, without needing to interpret, cross-check, or reason further. This matches the literal sense of on the face of it, the fact is visible on the face of the document itself, not buried beneath layers of construction or inference.
  3. Option C: This option describes a standard requiring the finder of fact to apply their mind and draw an inference. That is the opposite of what ex facie means, since an inferential process necessarily goes beyond the face of the document, while ex facie by definition stops at the surface.
  4. Option D: This option shifts the discussion to burden of proof, treating the standard as a presumption that need not be considered unless rebutted. Ex facie is not a burden-shifting device, it describes the manner of establishing a fact from the document itself, not who must disprove it.

Working through each option confirms that only the simple perusal reading is faithful to the plain meaning of ex facie, a fact that presents itself immediately upon looking at the document, without inference, interpretation, or burden-shifting.

Therefore, the correct answer is a standard where a document by very simple perusal displays the sought fact.

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Question: 7

In Lalita Kumari the Supreme Court provides a timeline for the completion of preliminary inquiries by the police prior to the registration of the F.I.R. As per the Court, such an inquiry should be concluded:

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In Lalita Kumari, “seven days” is the magic number for permissible preliminary inquiries.
Updated On: Jul 8, 2026
  • Within a period not exceeding fifteen days
  • Within a period not exceeding seven days
  • As expeditiously as possible but the Court did not specify a timeline
  • Within such time as may be permitted by the jurisdictional Magistrate
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The Correct Option is B

Approach Solution - 1

Step 1: Court’s directive in Lalita Kumari.
The Court set a strict timeline — preliminary inquiries, where permissible, must be completed within seven days to avoid undue delay in FIR registration. 
Step 2: Eliminate wrong options.
(A) Incorrect — 15 days was not prescribed in the judgment.
(C) Incorrect — Court did specify a limit (seven days).
(D) Incorrect — Magistrate’s permission is not the standard for inquiry duration. 
Step 3: Conclusion.
Therefore, \(\boxed{\text{(B)}}\) is correct.

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Approach Solution -2

The question asks for the specific outer limit the Supreme Court fixed in Lalita Kumari for completing a preliminary inquiry before registering an FIR. Let us test each option.

  1. Option A: A fifteen-day limit is not the figure that appears in the Constitution Bench's directions in Lalita Kumari. Fifteen days would be an unusually long window for what is meant to be only a preliminary, threshold-level check, and adopting such a long period would undercut the Court's stated concern that preliminary inquiry should not be allowed to delay FIR registration.
  2. Option B: The Constitution Bench specifically directed that where a preliminary inquiry is permissible, for example, in matrimonial, commercial, medical negligence, corruption, or similarly sensitive categories of cases, it must be completed within a period not exceeding seven days, with the reasons for delay to be recorded in the General Diary entry. This matches the precise figure fixed by the Court.
  3. Option C: This option suggests the Court left the timeline open-ended, requiring only that the inquiry proceed as expeditiously as possible. That is inconsistent with the Court's approach, since the entire point of prescribing a fixed period was to prevent open-ended delay in FIR registration, an outcome an unspecified timeline would not achieve.
  4. Option D: This option would make the length of the inquiry dependent on a Magistrate's permission on a case-by-case basis. Nothing in Lalita Kumari makes preliminary inquiry timing subject to a Magistrate's discretion, that mechanism does not feature in the Court's directions on this point at all.

Only the seven-day period matches the actual, express direction issued by the Constitution Bench, which fixed a firm ceiling precisely so that preliminary inquiry could not be used to indefinitely postpone registration of the FIR.

Therefore, the correct answer is within a period not exceeding seven days.

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Question: 8

An F.I.R. is considered the first information of the commission of a cognizable offence. Where the information discloses the commission of both cognizable offences as well as non-cognizable offences as part of the same facts, how must this information be treated?

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If any part of the facts in a complaint is cognizable, register the whole as FIR — separation happens later in investigation if needed.
Updated On: Jul 8, 2026
  • The entire information will be treated as disclosing cognizable offences and registered as an F.I.R.
  • The police officer will sever the parts disclosing non-cognizable offences and shall only register the parts disclosing cognizable offences.
  • The police officer shall refer the informant to the jurisdictional Magistrate for a direction to register the F.I.R., and thereafter, once such direction is received, register the F.I.R.
  • The F.I.R. registered, which contains information of non-cognizable offences, is subject to confirmation by a Magistrate under Sections 156 and 157 of Cr.P.C.
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The Correct Option is A

Approach Solution - 1

Step 1: Principle on mixed information.
When the facts disclosed include at least one cognizable offence, the entire set of facts is treated as cognizable for FIR purposes — splitting them is not required at the registration stage. 
Step 2: Eliminate wrong options.
(B) Incorrect — severance is not done at registration stage.
(C) Incorrect — referral to Magistrate is for purely non-cognizable cases.
(D) Incorrect — Sections 156 and 157 CrPC govern investigation procedure, not FIR confirmation. 
Step 3: Conclusion.
Thus, \(\boxed{\text{(A)}}\) is correct.

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Approach Solution -2

The question asks how the police must treat information that discloses both cognizable and non-cognizable offences arising out of the same set of facts. Let us examine each option.

  1. Option A: Where the facts disclosed include at least one cognizable offence, the police must register an FIR covering the entire transaction, without carving out or excluding the portions that describe non-cognizable conduct. This flows from the basic scheme of Section 154, which obliges registration once the information discloses a cognizable offence, and from the practical reality that criminal transactions are often a single continuous course of conduct that should not be artificially fragmented for registration purposes.
  2. Option B: This option proposes that the police sever the non-cognizable elements before registering the FIR. Such severance at the registration stage is not the procedure contemplated, splitting a composite set of facts into cognizable and non-cognizable parts before an FIR is even lodged would introduce exactly the kind of gatekeeping discretion that mandatory registration under Section 154 is meant to prevent.
  3. Option C: Referring the informant to a Magistrate for a direction before registration is the procedure associated with purely non-cognizable offences under Section 155, not with information that also disclosed a cognizable component. Since a cognizable offence is present here, this route does not apply.
  4. Option D: Sections 156 and 157 of the Cr.P.C. deal with the police's power to investigate a cognizable case and to proceed to the spot after registration, they are not provisions requiring a Magistrate to confirm an FIR once it is registered. This option misdescribes the function of those sections.

Since the presence of even one cognizable offence within the disclosed facts triggers the ordinary mandatory registration rule for the whole transaction, and none of the alternative procedures described in the other options apply at the registration stage, the composite information must be registered in full as a single FIR.

Therefore, the correct answer is the entire information will be treated as disclosing cognizable offences and registered as an F.I.R.

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Question: 9

The power of the police to launch an investigation is provided for under Sections 154 and 157 of Cr.P.C. The threshold to be met for launching an investigation under Section 157, according to Lalita Kumari, is:

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Think of Section 154 as “trigger to register” and Section 157 as “trigger to investigate” — the latter demands reason to suspect.
Updated On: Jul 8, 2026
  • Cogent and reliable information disclosing the commission of a cognizable offence.
  • Higher than the requirement under Section 154 of Cr.P.C. as the Section uses the term “reason to suspect the commission of an offence”.
  • Precisely the same standard under Section 154 of Cr.P.C. and the police have no discretion in the matter.
  • At the same standard as for a non-cognizable complaint being scrutinised by a Judicial Magistrate.
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The Correct Option is B

Approach Solution - 1

Step 1: Section 154 vs Section 157 threshold.
Section 154 mandates FIR registration when information discloses a cognizable offence. Section 157, however, deals with launching an investigation and uses “reason to suspect” — a slightly higher threshold requiring some preliminary satisfaction of suspicion. 
Step 2: Court’s interpretation in Lalita Kumari.
The Court recognised this difference, holding that while FIR registration is mandatory upon disclosure, investigation requires the officer to form a reasonable suspicion based on the information. 
Step 3: Conclusion.
Option (B) correctly reflects this higher threshold under Section 157 ⇒ \(\boxed{\text{(B)}}\).

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Approach Solution -2

The question asks how the threshold for launching an investigation under Section 157 of the Cr.P.C. compares with the threshold for registering an FIR under Section 154, as explained in Lalita Kumari. Let us examine each option.

  1. Option A: This option describes the threshold as requiring cogent and reliable information. That formulation does not track the statutory language of either Section 154 or Section 157, Section 154 requires only that the information disclose a cognizable offence, and Section 157 speaks of reason to suspect, neither of which is phrased in terms of the information being independently cogent or reliable at the threshold stage.
  2. Option B: Section 154 requires only that the information disclose the commission of a cognizable offence, at which point registration is mandatory. Section 157, by contrast, empowers the officer to proceed to investigate only where he has reason to suspect the commission of an offence, language that imports an element of the officer's own subjective satisfaction, over and above the bare disclosure that triggers registration. This makes the Section 157 threshold marginally higher than the Section 154 threshold, precisely as the Court explained in Lalita Kumari.
  3. Option C: This option asserts that the two thresholds are identical and that the police retain no discretion. That directly contradicts the differing statutory language of the two provisions, Section 154 is essentially non-discretionary once disclosure occurs, whereas Section 157 does allow the officer some room to form a reason to suspect before proceeding to investigate.
  4. Option D: This option equates the Section 157 threshold with the standard a Judicial Magistrate applies while scrutinising a non-cognizable complaint. That comparison is misplaced, Section 157 concerns the police officer's own threshold for launching an investigation into a cognizable case, it has nothing to do with a Magistrate's scrutiny of non-cognizable complaints, which follows an entirely different procedural track under Section 155.

Comparing the statutory language actually used in the two sections confirms that Section 157 sets a marginally higher bar than Section 154, since it conditions investigation on the officer's reason to suspect rather than the bare disclosure of an offence that triggers registration.

Therefore, the correct answer is higher than the requirement under Section 154 of Cr.P.C. as the Section uses the term reason to suspect the commission of an offence.

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Question: 10

According to the decision of the Supreme Court in Lalita Kumari, the police may not consider the genuineness of information disclosing the commission of a cognisable offence at the time of registering an F.I.R. What does this mean?

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FIR registration = face value test — truthfulness is for investigation, not registration.
Updated On: Jul 8, 2026
  • That the informant must be believed for the purposes of registering the F.I.R.
  • That the information must be taken as true for the purposes of registering the F.I.R.
  • That the police cannot reject any information disclosing the commission of a cognisable offence on the basis of it being false.
  • All the above
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The Correct Option is D

Approach Solution - 1

Step 1: Principle from Lalita Kumari.
At FIR registration stage, the only test is whether the information ex facie discloses a cognizable offence. The genuineness, credibility, or falsity of the information is irrelevant at this stage. |
Step 2: Implications for police.
(A) True — informant’s version must be accepted at face value for registration purposes.
(B) True — the statement is taken as true at the registration stage.
(C) True — police cannot refuse to register on grounds of suspected falsity. 
Step 3: Conclusion.
Since all three are correct, \(\boxed{\text{(D)}}\) is correct.

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Approach Solution -2

The question asks what it means to say that police may not consider the genuineness of information at the FIR registration stage, per Lalita Kumari. Since the final option asserts that all three preceding statements are correct, each must be tested independently on its own merits.

  1. Option A: If genuineness is irrelevant at registration, the practical corollary is that the informant's account must be taken at face value for the limited purpose of deciding whether to register the FIR, the officer is not permitted to first form a view on whether the informant is being truthful. This statement correctly captures one consequence of the rule.
  2. Option B: A closely related consequence is that the content of the information itself is treated as true for registration purposes, the officer's task at this stage is confined to checking whether the stated facts, if true, disclose a cognizable offence, not to independently verifying whether those facts actually occurred. This statement is also a correct restatement of the principle.
  3. Option C: The most direct consequence of the genuineness-is-irrelevant rule is that police cannot refuse registration on the ground that they suspect the complaint to be false, fabricated, or exaggerated, since any inquiry into truthfulness is deferred to the investigation stage that follows registration, not made a precondition for registration itself. This statement, too, is correct.
  4. Option D: Having confirmed that Options A, B, and C are each independently accurate descriptions of what genuineness is irrelevant at registration entails, from taking the informant at face value, to treating the stated facts as true, to being barred from rejecting the complaint as false, this option, which asserts that all three are correct together, is the most complete and accurate answer.

Since each of the first three statements independently and correctly describes a facet of the same underlying rule laid down in Lalita Kumari, none of them is wrong or redundant, they simply describe the same principle from three angles.

Therefore, the correct answer is All the above.

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