🏛️ Latest 2025 Supreme Court Judgment on Non-Registration of FIR

📌 Statement of Law by the Supreme Court
A police officer who fails to register an FIR despite having information which is sufficient to make him suspect that some cognizable offence has been committed is liable to be punished with imprisonment or fine or both.

📖 Case Overview

Delhi Law Academy Jaipur presents below a Summarized Version of the latest Supreme Court Judgment on “Non-registration of FIR” in the case of:

K. P. Tamilmaran v. State
Delivered by a two-judge Bench comprising Sudhanshu Dhulia and Prashant Kumar Mishra JJ on 28 April, 2025.

👉 Specially prepared for aspirants of RJS, DJS, PCS(J) and other Judicial Services across India.

⚖️ Case Title

K. P. Tamilmaran v. State
Judgment Date: 28 April 2025

🔎 Facts of the Case

• A young couple, Murugesan and Kannagi, were brutally murdered by poison in front of villagers.

• The crime was masterminded by Kannagi’s own father and brother because she, from the Vanniyar community, had married Murugesan, a Dalit.

• This was a case of so-called honour killing, rooted in caste prejudice.

• Incident: 7–8 July 2003

• Trial concluded: 24 September 2021 (after huge delays)

The Court noted:

• Gross inefficiency by prosecution + dilatory tactics by defence → extremely slow trial.

• Investigating Officer (A-15) fabricated evidence instead of collecting it lawfully.

• Clear violation of Sections 154 & 157(1) CrPC, and Sections 23 & 24 of the Police Act, 1861.

📜 Legal Principles Cited

Section 154(1) CrPC

• If a police officer receives information about a cognizable offence, he must reduce it in writing, read it over to the informant, and register the FIR.

Section 157(1) CrPC

• Police must forthwith send a report to the Magistrate and start investigation.

Supreme Court Precedent: Lalita Kumari v. Govt. of U.P. (2014)

• Registration of FIR is mandatory, even without a formal informant.

• FIR may also be registered by police suo motu (on their own information).

🚨 Application in Present Case

• Police Officers A-14 and A-15 had direct information of the double murder on 8 July 2003.

• Still, they did not register FIR.

• Their excuse (“nobody came forward to lodge complaint”) was rejected:

  1. Murugesan’s family did try to lodge FIR but were rebuffed with caste-based abuses.

  2. Even if no one reported, it was still their duty to register FIR.

Thus, their defence was found unsustainable.

⚖️ Section 217 IPC

“Whoever, being a public servant, knowingly disobeys any direction of the law as to the way in which he is to conduct himself … intending thereby to save, or knowing it to be likely that he will thereby save, any person from legal punishment … shall be punished with imprisonment … up to 2 years, or fine, or both.”

📝 Supreme Court’s Conclusion

• Both A-14 (K.P. Tamilmaran) and A-15 committed offences under Section 217 IPC.

• They neglected duty and deliberately disobeyed law by not registering the FIR.

• Their acts were intended to shield the guilty, and hence punishable.

🎯 Why This Judgment Matters for Judiciary Aspirants

• Reinforces mandatory registration of FIR principle.

• Demonstrates accountability of police under CrPC & IPC provisions.

• Crucial for RJS, DJS, and PCS(J) Mains exam prep (Essay + Criminal Law paper).

📚 Related Resources

👉 Study Material for Judiciary Exams
👉 Classroom Course for RJS in Jaipur