The Meghalaya High Court has strongly deprecated the practice of police authorities directing or registering First Information Reports (FIRs) under “appropriate sections” without first examining whether the allegations in a complaint actually disclose the commission of a cognizable offence. The Court emphasised that police officers must independently apply their mind to the allegations, determine whether the complaint reveals a cognizable offence, identify the appropriate legal provisions and only thereafter take a decision regarding registration of an FIR. The observation was made by Justice Revati Mohite Dere while dealing with a petition seeking quashing of FIRs registered against Professor Dr Ravi Kant Mishra. The judgment highlights the importance of proper application of mind at the very first stage of criminal proceedings.
The case arose from two complaints submitted by two law students of North-Eastern Hill University (NEHU) against Professor Dr Ravi Kant Mishra. The complaints were forwarded to the police with a direction to register them under the “appropriate section of law.” Following this, the police registered FIRs against the professor under Section 126(2) of the Bharatiya Nyaya Sanhita (BNS) on May 6, 2026. Dr Mishra subsequently approached the Meghalaya High Court challenging the FIRs and seeking their quashing. The proceedings therefore required the Court to examine not only the allegations contained in the complaints but also the manner in which the police proceeded to register the criminal cases.
A central issue considered by the High Court was whether the complaints themselves disclosed the commission of a cognizable offence. The Court found that they did not. This finding was particularly important because registration of an FIR carries significant legal consequences. Once an FIR is registered for a cognizable offence, the police can commence an investigation and take further steps in accordance with criminal procedure. Therefore, according to the Court, police authorities cannot mechanically register an FIR merely because a complaint has been forwarded to them with a general instruction to invoke the “appropriate sections” of law. They must first examine the allegations and determine whether the legal requirements for registration are actually satisfied.
Justice Revati Mohite Dere strongly criticised the practice adopted in the present matter. The Court made it clear that it is the responsibility of the police to first scrutinise the complaint and apply their own mind to the facts alleged. The police must determine whether the complaint discloses a cognizable offence and, if so, identify the relevant legal provisions before taking a decision on registration of the FIR. The Court’s observation places emphasis on the investigative responsibility of police officers and seeks to prevent FIR registration from becoming a purely mechanical or administrative exercise.
The Court’s criticism is significant because the expression “appropriate sections” can potentially leave the most important initial legal assessment incomplete. A police authority receiving a complaint must assess whether the allegations constitute an offence recognised by law and whether the offence is cognizable. Merely forwarding a complaint for registration under whatever sections may appear appropriate does not, by itself, fulfil the obligation to examine the allegations. The Meghalaya High Court’s ruling therefore stresses that the police must exercise independent judgment before setting criminal law into motion.
Another important aspect of the case was that the two complaints filed by the law students were identical. The High Court observed that, given the identical nature of the allegations, the police could not have registered two separate FIRs based on the same allegations. This observation adds another layer to the Court’s criticism of the manner in which the criminal proceedings were initiated. The Court directed the authorities to ensure that such a practice is not repeated in the future.
During the proceedings before the High Court, the two students also stated that they no longer wished to pursue their complaints. According to the report, they explained that the complaints had been made in an emotional outburst and were based on their misperceptions. Their subsequent decision not to pursue the matter became an additional factor considered by the Court while deciding the petition filed by Professor Mishra. The Court noted that the dispute between the parties had been amicably settled and that the complainants were unwilling to continue with the allegations.
After examining the circumstances, the Meghalaya High Court ultimately quashed the FIRs registered against Dr Mishra. The decision was based on the Court’s finding that the complaints did not disclose a cognizable offence warranting registration of an FIR, the fact that the two complaints were identical, and the subsequent settlement between the parties. The quashing of the FIRs brought an end to the criminal proceedings arising from the two complaints.
The Court also issued a specific direction concerning any future complaints that may be submitted by the two students against professors of the NEHU Law Faculty. It directed that such complaints should first be placed before the concerned Superintendents of Police before being taken to their logical conclusion. This direction appears intended to ensure greater scrutiny at the supervisory level and to prevent a repetition of the circumstances that resulted in the present proceedings. It also demonstrates the Court’s concern about ensuring that criminal complaints are appropriately evaluated before further legal action is initiated.
The ruling has broader significance for the criminal justice process because an FIR is often the starting point of a formal criminal investigation. An FIR can affect the reputation, professional standing and personal liberty of an individual, particularly where the allegations involve serious offences. The High Court’s insistence that police officers apply their minds before registering an FIR therefore reinforces the principle that criminal law should not be activated mechanically. A complaint must first be assessed on its own allegations and the legal ingredients of the offence alleged.
The judgment also highlights the importance of distinguishing between a complaint and a legally sustainable allegation of a cognizable offence. Every complaint received by the police does not automatically result in an FIR for a cognizable offence. The police must examine the factual assertions and determine whether they satisfy the legal requirements. If the allegations do not reveal a cognizable offence, the police cannot simply select a provision of criminal law and register an FIR without proper consideration. The Meghalaya High Court’s observations reinforce this basic but essential requirement of responsible criminal administration.
The issue becomes even more important in situations involving educational institutions, teachers and students, where disagreements or misunderstandings can sometimes result in complaints being made during emotionally charged circumstances. The present case demonstrates why complaints must be evaluated carefully and objectively. The fact that the two students later described their complaints as arising from an emotional outburst and misperceptions was relevant to the Court’s final consideration. However, the judgment does not mean that complaints made by students or other individuals should be ignored. Instead, it emphasises that every complaint should be examined according to law before criminal proceedings are initiated.
The Court’s comments regarding the two identical FIRs are also important from the perspective of procedural fairness. If two complaints contain substantially the same allegations arising from the same set of circumstances, registering separate FIRs may create unnecessary duplication and potentially expose the accused to multiple proceedings concerning the same allegations. The Court therefore directed the authorities to ensure that such a practice is not repeated. This direction reinforces the need for police authorities to examine the relationship between complaints before deciding how criminal proceedings should be initiated.
The case further demonstrates the supervisory role exercised by High Courts over criminal proceedings. When an accused person approaches the High Court seeking quashing of an FIR, the Court can examine whether continuation of the criminal proceedings is legally justified in the circumstances of the case. Here, the High Court found that the complaints themselves did not disclose a cognizable offence and that the registration process had been undertaken without the necessary application of mind. The subsequent settlement and unwillingness of the complainants to pursue the matter provided additional circumstances supporting the Court’s decision to bring the proceedings to an end.
At the same time, the decision should not be understood as establishing that every FIR can be quashed merely because a complainant later changes their position. The facts of each case are different, and the power to quash criminal proceedings depends upon the applicable legal principles and circumstances. In the present case, the Court’s decision rested on several factors taken together, including the absence of a cognizable offence in the complaints, the identical nature of the two complaints and the amicable settlement between the parties.
The judgment in Ravi Kant v. State of Meghalaya, Criminal Petition No. 91 of 2026, was decided on July 29, 2026. Justice Revati Mohite Dere’s observations provide a clear reminder that the police have an independent responsibility to evaluate complaints before registering FIRs. The ruling also sends an institutional message that criminal proceedings should be initiated only after the relevant authorities have carefully considered the allegations and the applicable provisions of law.
In conclusion, the Meghalaya High Court’s decision is significant for reinforcing the requirement that police authorities must apply their mind before registering an FIR. The Court strongly deprecated the practice of simply directing registration under “appropriate sections” without first determining whether the complaint discloses a cognizable offence. In the case involving Professor Dr Ravi Kant Mishra, the Court found that the complaints did not disclose such an offence, noted that the two complaints were identical, and took into account the students’ decision not to pursue the matter after an amicable settlement. The FIRs were consequently quashed, while safeguards were issued concerning any future complaints by the students against NEHU Law Faculty professors. The ruling ultimately underscores a fundamental principle of criminal procedure: the initiation of criminal proceedings must be based on careful legal assessment rather than a mechanical response to the filing or forwarding of a complaint.
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