The registration of a First Information Report (FIR) is the threshold event in the criminal justice process in Pakistan. It marks the point at which the law-enforcement machinery (typically the police) is formally notified of a cognizable offence and triggers investigation, possible arrest, and eventually trial. Given its importance, the courts have evolved a rich jurisprudence around the FIR: when it must be registered, by whom, in what form, the consequences of delay or defects, and the powers of courts (including the Lahore High Court) to direct or quash it.

The LHC Research Centre’s Criminal Citator (and the fortnightly Bulletins) serve as an authoritative digest of case law in Punjab and Pakistan broadly, and offer distilled statements of law and illustrative citations. For example, it states:

“Registration of F.I.R. is mandatory for the police officer u/s 154 Cr.P.C. in a cognizable offence.”

“Police cannot refuse to register a case on the ground that they consider the version to be false. S.H.O. must in cognizable case register and investigate it.”

This article will therefore examine the statute, the leading jurisprudence (including LHC-citated summaries), and the practical issues that arise in the field, particularly from the perspective of Punjab and the LHC region. The intent is to produce a resource for practitioners, scholars and students.

A. Statutory Framework

1. Section 154 Cr.P.C.

Under the Code of Criminal Procedure, 1898 (Cr.P.C.) the main provision on FIR is Section 154, which provides that:

when information is given to an officer-in-charge of a police station of the commission of a cognizable offence, he shall record the information in writing and read it over to the informant; and
The informant shall sign the copy of the entry.

The section thus casts a mandatory duty on police in cognizable offences to record FIR (or the police report of cognizable offence) once information is given.

2. Police Order, 2002 / Other statutory provisions

In certain jurisdictions, there is also the Police Order 2002 (in relevant provinces) or provincial amendments; for example, the Citator refers to “Article 155 of Police Order, 2002”. These provisions do not alter the core duty under Section 154 but may supplement the institutional regulation of policing.

3. Other relevant statutory or regulatory material

The old Police Act 1861 and the Punjab Police Rules 1934 continue to have relevance (especially for internal police rules) in many judgments. See Citator commentary.
The court’s jurisdiction under Articles 199/199/561-A Cr.P.C. to quash FIRs or to issue directions to register FIRs. For example, the Citator notes that “Registration of FIR & Taking cognizance, a different phenomenon.”

B. Key Legal Principles from the Citator / LHC Bulletins

Using the summaries in the LHC Criminal Citator and Bulletins, the following are the major distilled legal principles with citation pointers.

1. Mandatory nature of registration for cognizable offences

The Citator states: “Registration of F.I.R. is mandatory for the police officer u/s 154 Cr.P.C. in a cognizable offence (1993 SCMR 550).”
Further: “Police cannot refuse to register a case on the ground that they consider the version to be false. S.H.O. must in cognizable case register and investigate it.”
Inference: Once information indicates a cognizable offence, the police cannot decline registration on merits or assessment of truth; their duty is to register and investigate.

2. Distinction between registration (FIR) and cognizance / trial

“Registration of FIR & Taking cognizance, a different phenomenon.”
This is important: the FIR is simply the starting step of police investigation; it is not the same as the court taking cognizance and starting a trial. Many jurisprudential complications arise from conflating these stages.

3. Permissibility of court-directions for registration and limits of High Court powers

The Citator notes: “Registration of F.I.R. cannot be directed by High Court in all cases as other remedy is available by way of complaint to a Magistrate (PLJ 1977 Lahore 175).”
Inference: While courts (including High Courts) may in appropriate cases direct the police to register FIR, this is not an unlimited power. Alternative remedy of complaint before Magistrate remains available; indiscriminate directions to police to register may not always be appropriate.

4. Delay in lodging of FIR — its impact on credibility

The Citator summarizes: “Promptly made FIR eliminates possibility of fabrication (1975 SCMR 442). If there was any delay in lodging of FIR and commencement of investigation, it gave rise to a doubt, which could not be extended to anyone else except to the accused (PLD 2019 SC 64).”
Also: “Such FIR is not… registration after preliminary investigation… illegal act… loses its sanctity and credibility.”
Inference: Courts view delay, unexplained registration after investigation, ante-dating, and other anomalies concerning FIR registration with suspicion; these may affect evidentiary value though not automatically invalidate the FIR.

5. Multiple FIRs / second FIR issues

“Second FIR is prohibited (PLD 2018 SC 595).”
“All subsequent or divergent versions of the same occurrence or the persons involved therein are to be received, recorded and investigated by the investigating officer in the same ‘case’ which is based upon the one and only FIR.”
Inference: Law discourages multiple FIRs for the same incident and prefers that the investigative machinery deal with the matter in one case file. Use of multiple FIRs may raise questions of abuse or manipulation.

6. Form and content of FIR

“FIR must not be detailed. Minute details are not expected or necessary in the F.I.R. (PLD 1977 SC 529).” (Lahore High Court Research Center)
“Time and place not written in FIR… investigation from the very beginning was dishonest.”
Inference: While the FIR need not be heavy on detailed evidence, critical basic facts like approximate time, place, nature of offence, and persons involved should appear. Omission of such key particulars may weaken the FIR’s value.

7. Investigation before registration — impermissible

The Citator states: “The officer in charge of a police station has no right to undertake any pre-inquiry or pre-investigation but the course of investigation starts only after lodgment of the F.I.R. (2013 MLD 885).” (Lahore High Court Research Center)
Inference: The police may not delay registration by conducting an inquiry first and then lodging the FIR; such procedural workaround undermines the legislative duty and may raise the question of “registration after investigation” which courts frown upon.

8. Evidentiary value of FIR

“It is held by august Supreme Court that the contents of FIR were not a substantive piece of evidence (PLD 2016 SC 17).” (Lahore High Court Research Center)
“F.I.R. could not be given weight as substantive piece of evidence … but it could be looked into … as a relevant fact.”
Inference: While FIR is important for initiating investigation and for establishing some basic facts, it is not in itself substantive evidence unless further conditions (e.g., maker testifying, cross-examination) are satisfied.

8. Jurisdictional / territorial aspects of registration

For example, LHC reported: “Complainant got registered F.I.R. at Police Station “F.S”, district ‘S’ … cheque was deposited … No legal bar or prohibition existed on complainant/drawee in that regard; it was his option or choice … both police stations had got jurisdiction to lodge F.I.R.” (2010 PLD 60 LHC)
Inference: Complainants often have a choice regarding which police station to approach (subject to territorial jurisdiction). Mere registration at one station doesn’t per se invalidate the FIR where jurisdiction is satisfied.

9. High Court / writ / extraordinary relief context

The LHC Bulletins refer repeatedly to situations where the High Court (in exercise of writ jurisdiction) examines unexplained delays, ante-dating of FIR, and whether the complainant was unduly influenced, thereby affecting the reliability of FIR. (See e.g. Fortnightly Bulletin 1-15 May 2025 summarising “Unexplained and suspicious delay in the lodging of the FIR … renders the prosecution case unreliable”.)
Inference: While the FIR per se isn’t quashed lightly, High Courts exercise caution and may interfere in cases of manifest abuse, mala fide registration, or where fundamental rights of accused are threatened.

C. Major Jurisprudential Issues & Practical Implications

Here we examine some of the more noteworthy issues practitioners face, and the practical implications of the above principles.

1. When should the police refuse registration?

Given the mandatory nature of registration in cognizable offences, police cannot refuse to register just because they believe the version is false or improbable. The duty is to record the information, issue a copy of the FIR to the complainant, begin investigation and cause the matter to proceed. If the police refuse, the complainant may approach the Magistrate under Section 190/200 Cr.P.C for a complaint or / and approach High Court for writ (Art. 199) asking direction to register. But courts have held that High Court directions to police to register are not automatic or unlimited. (See Citator note: “Registration … cannot be directed by High Court in all cases as other remedy is available by way of complaint to a Magistrate”.)

Practical tip: If you represent a complainant whose FIR is refused, ensure you put in writing the information given, the fact of refusal, and seek remedy before Magistrate as initial step. When moving to High Court, show urgency, cognizable nature of offence, and that no alternative remedy suffices.

2. Delay and authenticity of FIR

Delay in lodging FIR is a recurring issue. The courts treat unexplained delay, ante-dating, overwriting of dates, or signs of manipulation as serious negative factors. For example, the LHC Bulletin (01-15 May 2025) summarises a case where the inquest report bore signs of interpolation, the FIR number was tampered, date overwritten, etc., and the FIR lost its value. (Lahore High Court Research Center)

Also the Citator states: “Such FIR is not only illegal act but also creates a serious doubt. FIR loses its sanctity and credibility.”

Practical tip for defence counsel: Investigate the date/time of FIR registration, examine inquest/post-mortem records, check if witness statements were recorded earlier or later, and whether investigation had begun prior to FIR. Raise these at the earliest stage (charge, bail) to undermine the FIR’s credibility.

3. Multiple FIRs for the same incident

As the Citator emphasises: “All subsequent or divergent versions of the same occurrence … to be recorded in the same case.”

And “Second FIR is prohibited (PLD 2018 SC 595).”

Practical tip: If your client is confronted with multiple FIRs arising out of same incident, you may argue they ought to be consolidated or that subsequent FIR should be disregarded for recklessness/abuse. For complainant, advise to lodge FIR early and uniformly.

4. Investigation preceding registration – problematic

The police may sometimes attempt “pre-inquiry” and then register an FIR. The Citator flags this as impermissible: “The officer in-charge … has no right to undertake any pre-inquiry or pre-investigation but the course of investigation starts only after lodgment of the F.I.R.”

Practical tip: Defence or complainant counsel should scrutinize if investigative steps (statements under s. 161 Cr.P.C., searches, recoveries) preceded lodging of the FIR. If yes, raise it as a ground of mala fide or prejudice in bail or at trial.

5. Territorial/subject-matter jurisdiction and choice of police station

The 2010 LHC decision (2010 PLD 60 LHC) held that where cheque dishonour occurred in one district but complainant had account in another district, registration in the latter police station was permissible.

Thus, a complainant often has an option among multiple territorial fora if the offence has effects in different places.

Practical tip for complainant counsel: Analyse all possible venues (where offence occurred, where complainant resides, where consequences occurred) and lodge FIR at most favourable police station. Defence counsel should verify territorial nexus and challenge if registration was in wholly irrelevant jurisdiction.

6. Evidentiary value of FIR at trial

While FIR is influential at the investigation and bail stage, courts are clear that it is not substantive evidence by itself. Citator: “Contents of FIR were not a substantive piece of evidence (PLD 2016 SC 17).” (Lahore High Court Research Center)

And: “F.I.R. could not be given weight as substantive piece of evidence … but it could be looked into … as a relevant fact.”

Practical tip: For defence, use this to argue that mere presence of an FIR doesn’t confirm guilt. For prosecution, ensure you build evidence beyond FIR: statements, recoveries, expert reports, etc.

7. High Court’s extraordinary jurisdiction (quash / direction)

LHC bulletins often summarise decisions where the High Court exercised writ jurisdiction (Art. 199) or revisional jurisdiction to quash an FIR or direct registration due to rights violations. For example, the bulletin (16-05-2023 to 31-05-2023) mentions “Registration of FIR as basis to issue a detention order.” (Lahore High Court Research Center)

However, the Citator emphasises limitations: the High Court cannot in every case direct registration of FIR simply because other remedy exists (complaint to Magistrate).

Practical tip: When considering a petition to High Court to quash or direct registration of FIR, ensure you build a strong case of illegality, mala fide, abuse of process or fundamental rights violation. The presence of alternate remedy may weigh against relief.

D. Practical Workflow: From FIR to Trial – What Counsel Should Do

Here is a step-by-step practical workflow, drawing from the above principles:

1. Complainant side

o On becoming aware of a cognizable offence, provide information to police station as soon as possible.

o Ensure your information includes approximate date/time, place, names if known, nature of offence, brief description.

o Obtain a copy of the FIR (Section 154 Cr.P.C.).

o Check the police station’s jurisdiction (territorial and subject-matter). If uncertain, you might approach any station where part of the offence occurred.

o If police refuse to register, first approach Magistrate under s. 200/190 Cr.P.C. and/or consider High Court petition for direction (but note limitations).

o After registration: monitor investigation, ask for updates (if possible), ensure no undue delay, check for pre-investigation irregularities.

2. Defence side

o As soon as client learns FIR lodged, obtain FIR copy and file for bail or anticipatory bail accordingly.

o Check timing of FIR: Is there unexplained delay? Are there signs of ante-dating or overwriting? (Bulletin examples show High Court scrutiny of such issues.)

o Check whether multiple FIRs/versus cross-versions exist for same incident – this may be used to challenge credibility.

o Check whether investigation commenced before registration (statements, recoveries) – if yes, may raise question of registration after investigation.

o Check jurisdiction of police station: if purely improper venue, raise challenge.

o At trial, emphasise that FIR contents are not substantive evidence; cross-examine maker of FIR/witness and seek to show inconsistencies/light-weight facts.

o Consider seeking quash of FIR in High Court only if strong case of mala fide, fundamental rights violation or manifest illegality.

3. For the Court / Judge

o On presentation of counsel, ensure FIR registration is compliant with s. 154 Cr.P.C. where cognizable offence alleged.

o If FIR is lodged with delay, look for explanation and raise question of credibility in due course (though not necessarily quashing).

o If direction to register FIR is sought, examine whether other remedies (complaint before Magistrate) exist and whether there is sufficient cause to exercise writ jurisdiction.

E. Recent Trends (Punjab / LHC region)

The latest Fortnightly Bulletins of the Lahore High Court Research Centre continue to emphasise that prompt registration of FIR for cognizable offences is essential; any delay, manipulation or ante-dating is treated with serious suspicion. For example, the Bulletin (01-15 May 2025) records that the High Court found “unexplained and suspicious delay in lodging of the FIR … renders the prosecution case unreliable.” (Lahore High Court Research Center)
The LHC’s Research Centre has also published that the “Criminal Law Citator” and associated bulletins assist judges in district and Sessions Courts to apply consistent precedent in FIR-related matters. (Lahore High Court Research Center)
A more recent bulletin (16-07-2025 to 31-07-2025) touches on new legislative/enforcement regimes (FIA Act etc.) but reaffirmed: “Under the general scheme of the Code of Criminal Procedure, a cognizable offence requires immediate registration of an FIR.” (Lahore High Court Research Center)
Inference: While the substantive principles remain stable, courts in Punjab are increasingly vigilant about procedural irregularities (delay, cross-versions, jurisdiction) in FIRs, especially at the bail / quash stage.

F. Challenges and Critiques

Police reluctance or selective registration: Despite the mandatory nature, there are instances where police are reluctant (due to political or social pressure) to register FIRs in cognizable offences. The Citator and LHC bulletins identify that refusal or delay is not permissible.
Quality of investigation after registration: Registration is only the first step; if investigation thereafter is perfunctory or delayed, the value of FIR may be undermined. Delays in statements, recoveries, etc., are critiqued by courts.
Multiplicity of FIRs and cross-versions: The insistence on one FIR per incident sometimes clashes with practical reality (multiple victims, cross complaints) and may create complexity.
Public confusion between FIR, cognizance, trial start: Many complainants believe registration of FIR means trial has begun; courts clarify that FIR is just the investigative trigger, not the judicial trial stage. (See the distinction in Citator).
Evidentiary weight vs. procedural weight: While importance of FIR is acknowledged, courts continue to emphasise that it is not substantive evidence per se. Sometimes practitioners confuse its procedural importance (for investigation/bail) with evidentiary weight (for conviction).
Territorial jurisdiction issues: The choice of police station may give rise to litigation on jurisdiction, especially in cheque-dishonour, cyber offences, or cross-district incidents. The LHC decision (2010 PLD 60 LHC) is illustrative.

Conclusion

The registration of an FIR is a critical cog in Pakistan’s criminal justice machine. The legislative mandate (Section 154 Cr.P.C.) compels the police to record information about cognizable offences, trigger investigation, and provide the complainant with a copy. The jurisprudence, as captured in the LHC Research Centre’s Criminal Citator and Bulletins, underscores several enduring principles: mandatory registration in cognizable cases, distinction between registration and trial, reserved power of High Courts to direct or quash FIRs (but with limits), the adverse effect of unexplained delay or procedural anomalies, caution in multiple FIRs, and graded evidentiary weight of the FIR at trial.

For practitioners, the key take-aways are: ensure early and proper registration; monitor for delays, antecedent investigation or ante-dating; check jurisdiction; challenge the FIR’s reliability where appropriate; and remember that registration is procedural, not ultimate proof of guilt. For courts, the responsibility lies in ensuring that the FIR mechanism is not abused, that complainants and accused both have fair access to justice, and that irregularities in registration are not overlooked.

In Punjab and before the Lahore High Court, the Citator and Bulletins provide a reliable compass for consistent application of these principles. They have helped streamline the jurisprudence in FIR-related matters and sharpen judicial scrutiny of defective registration. Ultimately, when the FIR system functions properly, it protects both state interests (in prompt investigation of crime) and individual rights (against unlawful arrest, delayed investigation, or abuse of process).

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Registration of a First Information Report (FIR)

Introduction