
Praveen Kumar
June 21, 2025 at 11:30 AM
*Amit Kumar V. Union of India (2025 SC)*
1. The investigations conducted u/s. 174 and 154 CrPC are distinct in nature, purpose and procedure.
2. The investigation u/s.154 CrPC begins with information about the commission of a cognizable offence, culminating in the registration of FIR and ending with filing of the final report u/s.173 CrPC. The purpose is to initiate the criminal justice system, collect evidence of the crime, and to take necessary actions against the offender.
3. Investigation u/s.174 CrPC is limited in scope and confined to finding only the “apparent cause of death”. The inquest proceedings u/s.174 CrPC are concerned with discovering whether in a given case the death was accidental, suicidal, homicidal, or caused by an animal and in what manner or by what weapon or instrument the injuries on the body appear to have been inflicted, therefore, the evidence taken is very short.
4. The SC held, relying upon *Lalita Kumari V. Government of UP (2014 SC)*, that once the Police receives information about the commission of a cognizable offence, it is imperative for the police to register the FIR and there is no scope for any preliminary inquiry.
5. In the present case, if the information disclosed allegations of abetment of suicide, the Police should have registered the FIR and it is *not* sufficient to close the entire matter only after undertaking an investigation u/s.174 CrPC.
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