The Andhra Pradesh High Court reaffirms existing precedent that once police register an FIR regarding a complaint, no further judicial orders are necessary for additional action on the same issue. This decision upholds settled law and clarifies the practical expectations for writs seeking FIR registration under Article 226, reinforcing binding precedent for all subordinate courts in Andhra Pradesh.
Summary
| Category | Data |
|---|---|
| Case Name | WP/22983/2025 of DHIKONDA LAKSHMI NARAYANA Vs The State of Andhra Pradesh |
| CNR | APHC010449522025 |
| Date of Registration | 29-08-2025 |
| Decision Date | 02-09-2025 |
| Disposal Nature | DISPOSED OF NO COSTS |
| Judgment Author | Dr. Justice Venkata Jyothirmai Pratapa |
| Court | High Court of Andhra Pradesh |
| Bench | Single Judge Bench |
| Precedent Value | Binding on subordinate courts in Andhra Pradesh |
| Overrules / Affirms | Affirms existing law regarding duty to register FIR and consequential writs |
| Type of Law | Criminal Procedure / Constitutional Law |
| Questions of Law | Whether a writ of mandamus can be issued for FIR registration when police have already registered a crime on the same facts. |
| Ratio Decidendi |
Once an FIR has been registered by the police pertaining to the petitioner’s complaint, the grievance stands redressed and no further writ relief is needed. The High Court, after hearing submissions from both sides, recorded the police’s compliance and disposed of the writ without costs. This reaffirms that judicial intervention is unnecessary once law enforcement has acted on a complaint by registering the FIR. The disposal is in line with prevailing jurisprudence under Article 226 for such matters. |
| Judgments Relied Upon | None cited |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Relied on procedural fairness and the recording of submissions regarding the police’s compliance with statutory duty. |
| Facts as Summarised by the Court | The petitioner complained that the police failed to register his complaint as an FIR and sought a writ of mandamus. The State submitted that FIR Cr.No.248/2025 had in fact been registered under specified sections against the parties named by the petitioner. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Andhra Pradesh |
| Persuasive For | Other High Courts, in matters concerning writs for FIR registration |
| Follows | Follows established precedent that writs under Article 226 are unnecessary if FIR already registered |
What’s New / What Lawyers Should Note
- Reaffirms that once the police have registered an FIR relating to a complaint, any pending writ seeking FIR registration is rendered infructuous.
- Lawyers should ensure actual FIR registration before drafting or continuing writs seeking such relief.
- Practical utility: In similar scenarios, courts are likely to dispose of writs upon confirmation of FIR registration without costs or further directions.
- Highlights the importance of verifying compliance through official submissions or records from State counsel.
Summary of Legal Reasoning
- The petitioner approached the High Court under Article 226, contending that police failed to register his complaint as an FIR.
- The Government’s advocate produced written instructions confirming that FIR Cr.No.248/2025 had already been registered under relevant criminal sections on the petitioner’s complaint against the relevant parties.
- The Court recorded this compliance, finding that the principal relief sought had already been achieved.
- Accordingly, it disposed of the petition without costs, following settled legal practice that judicial intervention is unnecessary when the statutory obligation (FIR registration) has been met.
- No further orders or directions were deemed necessary.
Arguments by the Parties
Petitioner
- Alleged that the police had not registered the complaint as an FIR.
- Sought a writ of mandamus to direct police to register the FIR and act on the complaint.
Respondent (State of Andhra Pradesh)
- Submitted, on written instructions, that Crime No.248/2025 for the relevant offences had already been registered against the parties named by the petitioner.
- Contended that, in light of the FIR registration, no further orders were necessary.
Factual Background
The petitioner lodged complaints dated 07-07-2025 and sent a reminder on 20-08-2025 to the police, alleging offences by respondents 6 and 7. Police initially did not register an FIR, prompting the petitioner to file a writ seeking a mandamus for FIR registration. During the hearing, the State submitted that FIR Cr.No.248/2025 had already been registered under relevant criminal law provisions against the named respondents.
Statutory Analysis
- The Court operated within Article 226 of the Constitution of India, considering the issuance of mandamus.
- The offences for which the FIR was registered included Sections 318(4), 316(2) BNS, and Section 5 of the Andhra Pradesh Protection of Depositors of Financial Establishments Act, 1999.
- The judgment reiterates that once compliance with registration of FIR is shown, no further statutory interpretation or intervention is warranted under writ jurisdiction.
Dissenting / Concurring Opinion Summary
None—single judge bench; no dissenting or concurring opinions reported.
Procedural Innovations
- The Court accepted written instructions as sufficient proof of FIR registration.
- Miscellaneous petitions related to the writ were automatically closed as a consequence of final disposal.
Alert Indicators
- ✔ Precedent Followed – The decision follows and applies existing precedent regarding the duty to register FIRs and the approach under Article 226.
Citations
- No SCC/AIR citation mentioned.
- CNR: APHC010449522025
- Order dated: 03.09.2025
- Reportable status not specified.