Lalita Kumari v. Government of UP

Not an RTI case — but a fixture of RTI practice: police and FIR records are among the most-requested categories, and this ruling defines what must exist before anything can be disclosed.

FIR registration mandatory upon information disclosing a cognisable offence.

• §154(1) CrPC leaves no room for discretion: if the information, as received, discloses a cognisable offence, registration follows. The officer's opinion about the information's truth does not enter at the registration stage.
• Preliminary inquiry — five illustrative categories: (a) matrimonial/family disputes; (b) commercial offences; © medical negligence; (d) corruption cases against public servants; (e) cases of abnormal delay in initiating prosecution. The page's earlier “seven categories” conflated the list with the seven-day outer limit — corrected. The Court added that these “are only illustrations and not exhaustive of all conditions which may warrant preliminary inquiry”. The gate is whether a cognisable offence is disclosed, not which box the case falls in.
• Seven-day cap on any preliminary inquiry, and its scope is limited to whether a cognisable offence is disclosed — not the veracity of the information.
• A refusal to register is itself actionable — the informant's remedies (supervisory complaint, magistrate under §156(3)/§190, writ) operate on top of the registration duty.

• The FIR copy is the anchor document. If registration is mandatory, a “no FIR was registered” reply to an RTI for the FIR copy is, in most matters, itself a red flag — take it to first appeal with this ruling in hand.
• Investigation status: RTI for the case diary, charge-sheet status and action-taken runs through §8(1)(h) — see Investigation and inquiry reports under RTI for the completion test.
• Refusal-to-register evidence: an RTI to the police station's diary/receipt register documents that a complaint was delivered and no FIR followed — the paper trail for a §156(3) application.
• Post-2024 note: the CrPC's FIR provision is now BNSS §173 (in force 1 July 2024), which carries its own preliminary-enquiry language; the Supreme Court has since clarified that Lalita Kumari does not require a preliminary inquiry in every case.

• Section 154 CrPC (now BNSS §173)
• See also §8(1)(h) of the RTI Act for the disclosure side

§154(1) CrPC: register or record reasons; five illustrative categories, seven-day preliminary inquiry; veracity is for investigation, not the registration desk.

No. Registration turns on whether the information *discloses* a cognisable offence, not on whether it is proved.

The core rule has been reaffirmed post-BNSS; the BNSS's own preliminary-enquiry language is being tested against it, and the Supreme Court has clarified Lalita Kumari is not an absolute pro-inquiry rule either.

Ask for the diary/receipt register entries for your complaint date, and copies of any GD entry — then first appeal; the register entries prove delivery and non-registration.

Any permissible preliminary inquiry must be concluded within seven days — it is a cap on the inquiry, not a waiting period before registration.

• Citation: (2014) 2 SCC 1
• Court: Supreme Court of India (Constitution Bench)
• Date: 2013-11-12
• Outcome: disposed
• Reporter / Cause-list: (2014) 2 SCC 1

• RTI Case-Law Search — full corpus
• PIO/FAA Knowledge Base
• 10 landmark Supreme Court RTI rulings
• High Court RTI rulings
• Landmark CIC decisions
• Investigation and inquiry reports under RTI
• RTI Act, 2005 — full text
• The RTI Playbook book

Last reviewed: 27 August 2026. The “seven categories” error corrected to the Court's five categories with the separate seven-day cap; RTI-use sections and FAQ added; BNSS note current to 2025 clarifications.