Allahabad HC: SC/ST Status Alone Not Enough To Direct FIR Registration, Courts Must Examine Facts

Prayagraj, March 12: The Allahabad High Court has clarified that merely because a complainant belongs to the Scheduled Caste or Scheduled Tribe (SC/ST) community, courts are not automatically required to order the registration of a First Information Report (FIR).

The court said that the direction to register an FIR cannot be issued mechanically and must be based on proper examination of the facts presented in the case.

Case related to dispute in Azamgarh

The observation was made while hearing a criminal appeal related to a dispute from Azamgarh district. The petitioner had challenged an order of the Special Judge under the SC/ST Act, who had refused to direct the police to register an FIR based on the complaint submitted before the court.

Court stresses application of judicial mind

While hearing the matter, the bench observed that courts must apply their judicial mind before issuing such directions. It emphasized that the mere mention that the victim belongs to the SC/ST community does not automatically make it mandatory for the court to order a police investigation.

The court further noted that under the Bharatiya Nagarik Suraksha Sanhita (BNSS), which replaced the Criminal Procedure Code provisions related to investigation, a magistrate has the discretion to either direct police investigation or treat the matter as a complaint case and proceed accordingly.

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Judges must examine evidence and circumstances

The High Court also stated that judges must carefully examine the allegations, available evidence and circumstances before deciding whether police investigation is necessary. Courts, it said, cannot act as a “mere conduit” for directing registration of FIRs.

After considering the arguments of both sides, the High Court upheld the decision of the lower court and dismissed the appeal, reiterating that judicial discretion must be exercised after proper evaluation of each case.