S.156(3) CrPC | FIR Order Valid Even If S.154(3) Not Used: SC

S.156(3) CrPC | FIR Order Valid Even If S.154(3) Not Used: SC

In Anurag Bhatnagar & Anr. vs. State (NCT of Delhi) & Anr., the Supreme Court held that a Magistrate’s order to register an FIR under Section 156(3) CrPC is not invalid merely because the complainant did not first pursue remedies under Section 154(3). While approaching the police and Superintendent of Police is preferred, a direct approach to the Magistrate is not fatal if the court has jurisdiction. The Court stressed that Magistrates must issue speaking, reasoned orders reflecting judicial application of mind. It also ruled that courts should not quash FIRs post-investigation unless clear illegality exists. Distinguishing civil from criminal disputes, it held that allegations of fraud, inducement, and conspiracy can invoke criminal liability, even if rooted in contractual issues. Multiple FIRs are valid if filed on different facts, at different stations, or involving new parties. Dismissing all SLPs, the Court upheld the FIR and refused to interfere with the High Court's decision.