Police Cannot Refuse FIR If Complaint Discloses Cognizable Offence, Even If It Appears Imaginary: Supreme Court In IIT Delhi Suicides Case

Police could not have taken a shortcut just because something happened in the hostel of an eminent educational institution like IIT Delhi - Supreme Court of India rebuking the Delhi Police and IIT Delhi administration for their failure to register FIRs in connection with the suicides of two Scheduled Caste students. The Court emphasized the mandatory nature of FIR registration under Section 154 of the CrPC, stating unequivocally that “if any information disclosing a cognizable offence is laid before an officer in charge of a police station… the said police officer has no other option except to register a case.”
In a scathing critique of institutional apathy, the Division Bench of Justices J.B. Pardiwala and R. Mahadevan directed immediate FIR registration based on complaints alleging caste-based discrimination and abetment to suicide, holding that the investigation under Section 174 CrPC cannot substitute a full-fledged criminal investigation.
The case stemmed from the suicides of two IIT Delhi students, Ayush Ashna and Anil Kumar, on 8 July 2023 and 1 September 2023, respectively. Their families had filed detailed complaints before the local police, alleging harassment and caste-based discrimination, particularly from faculty and fellow students.
Despite receiving specific allegations including use of casteist slurs, mental harassment, and discriminatory treatment, the Delhi Police did not register any FIR. Instead, they treated the deaths as simple cases of unnatural death, carrying out only inquest proceedings under Section 174 CrPC.
The families alleged that this was a clear violation of their rights under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, and CrPC, and approached the Supreme Court after the Delhi High Court refused to intervene.
The Court was confronted with the central issue: whether the Delhi Police was justified in not registering an FIR despite allegations of cognizable offences, and whether such refusal violated statutory and constitutional duties.
Referring to the statutory framework, the Court declared: “Registration of an F.I.R. is mandatory under Section 154 of the Code, if the information discloses commission of a cognizable offence and no preliminary inquiry is permissible in such a situation.”
On the limited scope of inquest proceedings under Section 174 CrPC, the Court reiterated the principle laid down in Pedda Narayana v. State of Andhra Pradesh (1975) 4 SCC 153, stating: “The question regarding the details as to how the deceased was assaulted or who assaulted him or under what circumstances he was assaulted appears to us to be foreign to the ambit and scope of the proceedings under Section 174.”
The Bench strongly disapproved the closure of investigation based on such inquest alone, stating: “To close the entire matter after undertaking an investigation under Section 174 of the CrPC is something which we do not approve of.”
On the nature of FIR registration under Section 154 CrPC, the Court quoted from State of Haryana v. Bhajan Lal, emphasizing: “The police officer concerned cannot embark upon an enquiry as to whether the information laid by the informant is reliable and genuine or otherwise… The officer is statutorily obliged to register a case.”
Reinforcing the principle laid down in Lalita Kumari v. Government of U.P., (2014) 2 SCC 1, the Court said: “There is no discretion or option left with the police to register or not to register an FIR once information of a cognizable offence has been provided.”
Addressing the specific context of the SC/ST (PoA) Act, the Court noted: “Section 18-A of the said Act mandates that no preliminary enquiry shall be required for registration of a First Information Report against any person.”
The Court rebuked the police for neglecting this statutory mandate, holding that: “Even if the Police was of the view that there was no element of truth in what had been alleged by the appellants, it could have said so only after registering an F.I.R. and conducting an investigation.”
The Supreme Court highlighted the dual responsibility of both educational institutions and law enforcement agencies in handling such sensitive matters, observing: “It becomes their unequivocal duty to promptly lodge an F.I.R. with the appropriate authorities. Such action is not only a legal obligation but also a moral imperative to ensure transparency, accountability, and the pursuit of justice.”
Accordingly, the Court issued the following direction: “We direct the DCP (South-West District, New Delhi) to register the First Information Report in line with two respective complaints lodged in writing by the kith and kin of the two students who committed suicide.”

A National Task Force To Address Rising Student Suicides
Deeply alarmed by the rising pattern of student suicides, the Court went beyond the immediate facts of the case and directed the constitution of a National Task Force to investigate mental health concerns, caste discrimination, ragging, academic stress, and related causes behind student suicides.
“The nation has already suffered the tragic loss of numerous students – young individuals with immense potential… due to the absence of adequate institutional support.”
The Bench observed: “Universities must act in loco parentis… not just to ensure academic excellence of the students but also to ensure their mental well-being.”
It noted: “Caste-based discrimination on college campuses is in clear violation of Article 15 of the Constitution.”
Quoting the Ministry of Education’s data, the Court took judicial notice that: “Out of 98 student suicides in higher educational institutes since 2018, 39 were from IITs, 25 from NITs, 25 from central universities…”
The Court referred to a study by Pune International Centre, stating: “70% of faculty members across IITs felt ill-equipped to address mental health issues, and 90% lacked proper training.”
Accordingly, the Court constituted a Task Force chaired by Justice S. Ravindra Bhat (Retd.), including psychiatrists, educationists, disability rights experts, legal scholars, and senior government officials.
The Task Force was mandated to: “Prepare a comprehensive report… to identify causes of student suicides, analyze existing institutional mechanisms, and recommend reforms.”
It was granted the power to conduct surprise inspections, engage research staff, consult stakeholders, and submit interim and final reports within 4 and 8 months respectively.
The Court concluded with a stern message to institutions and government bodies: “We direct the Central Government, the Governments of all the States/Union Territories and agencies thereof, and Universities to extend their full and active cooperation to the Task Force.”
This judgment stands as a strong reaffirmation of the rule of law, reminding authorities that no individual or institution is above legal obligation. By holding that failure to register an FIR in the face of cognizable offences is impermissible, the Court has restored hope for accountability and justice for the marginalized.

In the words of the Bench: “It is imperative for institutions to have a culture of sensitivity and proactive intervention so that every student feels safe, supported, and empowered to pursue their aspirations without fear or discrimination.”

Date of Decision: 24th March 2025