Section 166A IPC strictly applies to specified offences and does not cover failure to register FIR for forgery.

The petitioner (complainant) alleged that his grandmother’s Will, bequeathing him property, was bypassed through a forged report by a Patwari and a subsequent mutation attested by the Tehsildar in favor of other relatives

The complainant reported the alleged forgery and cheating to the police, but no FIR was registered

Consequently, he filed a complaint before the Chief Judicial Magistrate, Bilaspur, seeking action under Section 166A(b) of the IPC against the public servants for failing to register the FIR

The Trial Court dismissed the complaint on November 10, 2025, holding that the alleged offences (forgery and cheating) do not trigger Section 166A

The petitioner approached the High Court in revision, arguing that mandatory registration of FIR is required under the Lalita Kumari precedent

1. Whether a public servant can be prosecuted under Section 166A of the IPC for failing to register an FIR regarding offences not specifically listed within that section (such as forgery/cheating)

2. Whether the act of failing to register an FIR constitutes a violation of "investigation" procedures under Section 166A(b) of the IPC

The Court applied Section 166A of the IPC, which penalizes public servants for disobeying law directions, specifically sub-section (c) regarding failure to record information for specified cognizable offences against women and children

It relied on Mohd. Wajid v. State of U.P. [2023] regarding the strict construction of penal statutes

It further utilized the principles from Lalita Kumari v. Govt. of U.P. [2014], which clarified that Section 166A(c) is limited to the specific sections mentioned therein

Rizwan Khan v. State of C.G. [2018], which established that an FIR is not part of the "investigation" but precedes it

The Court reasoned that penal statutes must be construed strictly; thus, the scope of Section 166A cannot be expanded to include offences like forgery or cheating which are omitted from the text of the statute

Referring to Lalita Kumari, the Court noted that the legislature specifically inserted Section 166A(c) to punitively ensure FIR registration for crimes against women, and no other meaning can be assigned to it

Regarding the petitioner's argument under Section 166A(b)—which concerns the "manner" of investigation—the Court held that an FIR is a prerequisite to an investigation and not a part of the investigation itself

Therefore, a failure to register an FIR cannot be termed a procedural lapse in the conduct of an investigation under Section 166A(b)

The High Court dismissed the revision petition, affirming the Trial Court's order

The Court confirmed that there was no patent defect or error of jurisdiction in the Trial Court’s dismissal