Delayed FIR registration despite Magistrate’s direction constitutes serious dereliction of duty warranting adequate disciplinary action.

The petitioners filed a writ petition (Criminal) seeking to quash an order dated 07.03.2026 passed by the Judicial Magistrate First Class (JMFC), Durg, in MJC Criminal Case No. 80 of 2026.

During the proceedings, it was revealed that despite the JMFC’s direction on 07.03.2026 to register an FIR, the police delayed the registration until 23.03.2026.

Following a court order dated 23.03.2026, the Director General of Police (DGP), Chhattisgarh, filed a personal affidavit stating that FIR No. 0151/2026 was eventually registered under the Bharatiya Nyaya Sanhita (BNS), 2023.

The DGP further informed the Court that disciplinary action had been initiated against Inspector Navin Rajput (SHO, P.S. Kotwali) for dereliction of duty regarding the delay.

In light of these developments, the petitioners sought to withdraw the petition.

1. Whether the order dated 07.03.2026 passed by the JMFC, Durg, directing the registration of an FIR, was liable to be quashed.

2. Whether the delay in registering the FIR by the concerned Police Officer constituted a dereliction of duty requiring judicial intervention and departmental oversight.

The Court considered the provisions of Section 318(4) (Cheating) and Section 3(5) (Joint Liability/Common Intention) of the Bharatiya Nyaya Sanhita (BNS), 2023, under which the FIR was registered.

It also applied the principle of judicial oversight over police conduct, emphasizing that directions issued by a Magistrate for the registration of an FIR must be complied with immediately.

The Court observed that the primary relief sought—the quashing of the JMFC's order—had become secondary to the procedural developments where the FIR had already been registered on 23.03.2026 in compliance with the lower court's directions.

The High Court scrutinized the conduct of the Station House Officer (SHO), noting that the delay in registration was a serious "dereliction of duty".

While the Senior Superintendent of Police (SSP) had initially imposed a punishment on the officer, the Court found it "inadequate" considering the gravity of the misconduct.

The Court utilized its supervisory jurisdiction to direct the Inspector General of Police (IGP) to review and reconsider the adequacy of the disciplinary action to ensure administrative accountability.

The Court further directed the Inspector General of Police, Durg Range, to review the disciplinary proceedings against Inspector Navin Rajput and file a personal affidavit before the Registrar General within four weeks detailing the outcome of said review.