Delhi HC Bars Unverified Police Database Report As Proof Of Man’s Involvement In FIR That Does Not Name Him, Until Verified

In brief

The question

Whether FIR No. 215/2025 could be quashed qua the petitioner when he was not named as an accused and there was no material showing that he had subsequently been arrayed as one.

The court held

The Court did not quash FIR No. 215/2025 qua the petitioner, but directed the DCP, IGI Airport, to verify the database entry; the petitioner was directed to cooperate, and any erroneous entry was to be corrected.

It also directed

The verification outcome was to be communicated to the petitioner within four weeks.

Pending verification, Report No. 5848009 could not be relied upon or placed before any court as proof of the petitioner’s involvement in FIR No. 215/2025.

The petition and pending application were disposed of.

01Facts

FIR No. 215/2025, registered at Police Station IGI Airport under Sections 318(4), 336(3) and 340(2) of the Bharatiya Nyaya Sanhita, 2023, read with Section 12 of the Passports Act, 1967, initially named only Dharampal Singh; the petitioner was not named as an accused.

¶ 4

An internal Previous Conviction/Involvement Report attributed the FIR to the petitioner under “Criminal Attributes DataBase,” while recording “Not Found / No Row Selected” under the other listed databases.

¶ 5

The report had been placed on record in the petitioner’s pending anticipatory-bail proceedings in another FIR.

¶ 6–7

The petitioner sought to quash FIR No. 215/2025 insofar as it concerned him and to prevent reliance on, and obtain correction of, the database entry.

¶ 1

02Issues

i.Whether FIR No. 215/2025 could be quashed qua the petitioner when he was not named as an accused and there was no material showing that he had subsequently been arrayed as one.

¶ 8

ii.Whether the internal report attributing the FIR to the petitioner could be relied upon as proof of his involvement, and whether the database entry required verification and possible correction.

¶ 9–10

03Law Applied

The Court considered FIR No. 215/2025, registered under Sections 318(4), 336(3) and 340(2) of the Bharatiya Nyaya Sanhita, 2023, read with Section 12 of the Passports Act, 1967.

¶ 4

It applied the principle that there is no occasion to quash an FIR qua a person who is not named as an accused where nothing shows that the person has been arrayed as one.

¶ 8

It also held that an unverified internal report which is designated solely for investigating officers’ reference, requires verification by the concerned police station, and is not to be submitted to a court or government agency cannot be treated as proof of involvement in a criminal case.

¶ 9

Provisions in the judgment · 4 · Linked ones open on LawLens

Bharatiya Nyaya Sanhita, 2023 Section 318 Section 336 Section 340

Passports Act, 1967 Section 12

04Reasoning

Because the petitioner was neither named in FIR No. 215/2025 nor shown to have been made an accused in it, the Court found no basis to quash the FIR qua him at that stage.

¶ 4, 8

The report’s own limitations, together with the fact that the attribution appeared only under one database heading, meant it could not establish the petitioner’s involvement without verification.

¶ 5, 9

The Court therefore directed the concerned DCP, IGI Airport, to verify the entry against the records of FIR No. 215/2025 and, if necessary, FIR No. 551/2019.

¶ 10

05Holding

¶ 8, 10–11

The verification outcome was to be communicated to the petitioner within four weeks.

¶ 12

Pending verification, Report No. 5848009 could not be relied upon or placed before any court as proof of the petitioner’s involvement in FIR No. 215/2025.

¶ 13

The petition and pending application were disposed of.

¶ 14

LawLens.Delhi High Court

Original Court PDF