FIR registration depends on whether the complaint discloses a cognizable offence, despite any contractual dimension.

The petitioner claimed to have purchased a Mahindra Bolero Pik-Up and, under a rent agreement dated 17 July 2025, entrusted it to respondent No. 4.

He alleged that respondent No. 4 failed to pay the agreed rent of ₹2,10,000, that a cheque issued for the rental amount was dishonoured for insufficiency of funds, and that the vehicle was not returned after the agreement expired.

After allegedly receiving no action on his complaint to the Station House Officer, the petitioner submitted a representation to the Superintendent of Police, Umaria, on 1 June 2026.

He sought consideration of that representation, registration of an FIR, and return of the vehicle.

Whether the Superintendent of Police should be directed to consider the petitioner’s representation and act in accordance with law, including whether the allegations disclose a cognizable offence.

Whether the Court should direct respondent No. 4 to hand over the vehicle to the petitioner in the writ petition.

Under Section 154 of the Code of Criminal Procedure, 1973, registration of an FIR is mandatory where information discloses the commission of a cognizable offence, as held in Lalita Kumari v. Government of Uttar Pradesh, (2014) 2 SCC 1.

Where the information does not clearly disclose such an offence but indicates the need for further inquiry, the police must proceed in accordance with the principles in Lalita Kumari and applicable statutory provisions.

A dispute’s civil or contractual dimension does not, by itself, permit the police to disregard information that discloses a cognizable offence.

The Court treated the allegations concerning non-payment, cheque dishonour, and retention of the vehicle as matters requiring assessment by the competent police authority; those allegations alone did not enable the Court to conclusively determine whether a cognizable offence had been disclosed.

It therefore directed the Superintendent of Police to consider the representation under the principles in Lalita Kumari, without itself ordering registration of an FIR.

The vehicle-return claim involved disputed contractual rights and entitlement to possession, which the Court considered unsuitable for determination in this writ petition.

If the information discloses a cognizable offence, the competent authority must proceed accordingly.

The Court expressed no view on the merits or liability of respondent No. 4 and declined to direct return of the vehicle, without prejudice to the petitioner’s other remedies.