State of Haryana v. Bhajan Lal

The Supreme Court held that when a complaint shows a cognizable offence on its face, the police must register an FIR under Section 154 CrPC. At that early stage, the police do not test the truth of facts; they only see if an offence is disclosed. The High Court’s power to quash criminal proceedings exists, but it is exceptional and must be used sparingly.

1. Do the allegations, taken as they are, disclose a cognizable offence so that police can investigate?
2. Was the High Court right in quashing the FIR and proceedings under Article 226 and Section 482 CrPC? If not, what is the correct limit of those powers?

• Section 154(1) CrPC: If information discloses a cognizable offence, registering FIR is mandatory.
• Section 156 CrPC: Officer in charge may investigate a cognizable case and submit a report to the Magistrate.
• Quashing power (Art. 226 / Sec. 482): Use in rarest of rare situations to prevent abuse of process; not to assess reliability of facts at the start.
• Police primacy in investigation: State of Bihar v. J.A.C. Saldanha—investigation is the police/executive field; courts do not manage day-to-day investigation.

The Supreme Court set aside the High Court’s order. The complaint, on its face, showed offences of corruption and misconduct. Hence, the FIR was mandatory and investigation could continue. The Court reminded that quashing is reserved for clear cases where no offence is made out or the process is clearly abused.

• At FIR stage, the test is disclosure of a cognizable offence, not proof or reliability.
• Police have the primary duty and power to investigate cognizable offences (Sec. 156 CrPC).
• High Court’s power to quash must be used sparingly, mainly to prevent abuse or when the complaint does not disclose any offence.

Supported by State of Bihar v. J.A.C. Saldanha on police primacy in investigation.

This case is the go-to authority for FIR registration and limits on early quashing. It protects the flow of investigation in serious offences while keeping a narrow safety valve against misuse.

• FIR is compulsory if information reveals a cognizable offence (Sec. 154).
• Investigation = police domain (Sec. 156); courts avoid micro-managing.
• Quashing = exception, not a shortcut to test truth of facts.

Mnemonic: “First Inform, then Research” → FIR before proof.

1. Flag the offence (Does it disclose a cognizable offence?).
2. Investigate (Police step in under Sec. 156).
3. Rare Quash (High Court steps in only to stop abuse or no offence).

Cognizable Offence

Police can register FIR and arrest without warrant.

FIR (Section 154)

First report to police when a cognizable offence appears from the information.

Quashing

High Court power to stop criminal proceedings to prevent abuse or injustice.