The Supreme Court recently in Dharmendra Kumar @ Dhamma v. State of Madhya Pradesh [2024] 7 S.C.R. 218 : 2024 INSC 480 reaffirmed that FIR is not a substantive evidence, and elaborated the significance of registration of FIRs for offences. It held that it needs to be borne in mind that FIR is not a substantive piece of evidence, and it can be used only to corroborate or contradict the version of an Informant. It is also not necessary that there should always be a written complaint to register the FIR. Even an oral communication to the Police disclosing the commission of a cognizable offence is sufficient to register the FIR.
It explained the significance of registration of FIRs in the following words:
“that the object of the FIR is three-fold :-
firstly, to inform the jurisdictional Magistrate and the Police Administration of the offence that has been reported to the Police Station;
secondly, to acquaint the Judicial Officer before whom the case is ultimately tried as to what are the actual facts stated immediately after the occurrence and on what materials the investigation commenced;
thirdly and most importantly, to safeguard the accused against subsequent variations, exaggerations or additions.”