Supreme Court Annual Digest 2025 [Part-II]: Police Duty to Register FIR Under Section 154 CrPC Highlighted

New Delhi: In its latest 2025 Annual Digest [Part-II], the Supreme Court of India underscored the fundamental duty of police officers to act swiftly and impartially when informed about cognizable offences, reiterating established legal principles under Section 154 of the Code of Criminal Procedure (CrPC). The observations form part of the comprehensive annual review of key judgements released by the apex court.

Police as ‘Sentinels of the Law’

The court reiterated that police officers are the frontline protectors of public order and justice and must discharge their duties vigilantly, promptly and objectively, without allowing personal biases or discretion to override legal obligations. Any failure to do so, particularly in recording a First Information Report (FIR) when credible information about a cognizable offence is presented, amounts to a “dereliction of duty.”

Clear Legal Mandate in Section 154 CrPC

Under Section 154 of the CrPC, the law mandates that any information relating to the commission of a cognizable offence — whether provided orally or in writing to the officer in charge of a police station — must be reduced to writing and entered in the station diary. When such information discloses the commission of a cognizable offence, the police are duty-bound to register it as an FIR.

The Supreme Court has consistently upheld this principle, initially articulated in landmark judgments such as Lalita Kumari v. Government of Uttar Pradesh (2014), which held that no preliminary inquiry is permissible where the information clearly discloses a cognizable offence. This principle continues to guide police reporting duties under Section 154.

Why FIR Registration Matters

An FIR is not just a procedural formality — it triggers the criminal justice process. Once registered, it compels the police to investigate the matter promptly, gather evidence, and lay the foundation for prosecution. Failing to register a valid complaint on time can hinder evidence collection, delay justice, and erode public confidence in law enforcement.

Accountability for Police Inaction

The Supreme Court’s remarks in the Digest go beyond theoretical guidance. By describing refusal to register FIRs as dereliction of duty, the court has signalled that inaction or willful negligence by police in cognizable matters will attract scrutiny and possible corrective orders from higher courts. This follows a line of Supreme Court decisions emphasizing accountability in police conduct under CrPC.

Broader Context

This part of the Annual Digest relates to Section 173 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) — the new statutory framework corresponding to CrPC provisions — but confirms that the time-honoured duty of prompt FIR registration remains central to criminal law enforcement in India.

Legal commentators say the Digest’s emphasis on police obligation reinforces long-standing jurisprudence and serves as a stern reminder to law enforcement that procedural negligence in FIR registration undermines the rule of law and access to justice for victims.