Anurag Bhatnagar v. State (NCT of Delhi) 2025 INSC 895 - Ss.154,156 CrPC - FIR - Reasoned Order By Magistrate

Code of Criminal Procedure, 1973 (CrPC) - Section 154,156 - The Magistrate ought not to ordinarily entertain an application under Section 156(3) CrPC directly unless the informant has availed and exhausted his remedies provided under Section 154(3) CrPC, but as the Magistrate is otherwise competent under Section 156(3) CrPC to direct the registration of an FIR if the allegations in the application/complaint discloses the commission of a cognizable offence, the order so passed by the Magistrate would not be without jurisdiction and would not stand vitiated on this count. (Para 33)

Code of Criminal Procedure, 1973 (CrPC) - Section 154,156 -A reasoned order upon application of judicious mind is inherent while passing an order under Section 156(3) of the CrPC. (Para 35)

Interpretation of Statutes - Merely because a judgment by the Court has simply interpreted and reiterated the established principles of law that ought to have been into practice, it would not mean that such principles would be applicable prospectively only from the date of its interpretation. The interpretation made later on would not mean that the provision had a different meaning prior to its above interpretation. (Para 38)

Code of Criminal Procedure, 1973 (CrPC) - Section 300 - Section 300 CrPC debars a second trial. This is based on the public policy that no one should be harassed twice for the same offence by putting him to trial again and again. (Para 52) But complainant not debarred from preferring a second complaint on the same allegations if the first complaint did not result in conviction, acquittal or even discharge. However, when a complaint is dismissed on merits, a second complaint on the same facts cannot be made except in a very exceptional circumstance. (Para 53) Successive FIRs in respect of a same cognizable offence are not maintainable provided that on the basis of the earlier FIR, investigations have been completed and the trial had either resulted in conviction or acquittal of the accused.(Para 54)

Code of Criminal Procedure, 1973 (CrPC) - Section 154 -When information of the commission of the same offence was given to the police at two different places, by different persons and at different times, both the reports will be independent First Information Reports- Referred to in State of Bombay vs. Rusy Mistry. (Para 56) Successive FIRs in respect of a same cognizable offence are not maintainable provided that on the basis of the earlier FIR, investigations have been completed and the trial had either resulted in conviction or acquittal of the accused.(Para 54)

Code of Criminal Procedure, 1973 (CrPC) - Section 482- The powers vested in the court either under Section 482 CrPC or Article 226/227 of the Constitution of India are not for the purposes of appreciating the evidence or examining the correctness of the evidence collected during investigation to record a different conclusion other than recorded by the Magistrate that he is satisfied that a cognizable offence has been disclosed in the application/complaint. Moreover, when information disclosing commission of cognizable offence is conveyed to the police station, the officer-in-charge of the police station cannot refuse to register the FIR. Therefore, if an FIR has not been registered for any reason at the police station and the Magistrate is satisfied that the information discloses a cognizable offence, he can certainly direct for its registration obviously on compliance of the provisions of Section 154(3) of the CrPC. (Para 40)

Natural Justice- A speaking order is a part and an essential component of the principles of natural justice, which are applicable to every judicial order. (Para 38)

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