Say the ratio out loud before you open Reasoning — recalling it unprompted is exactly what the exam pays for.
Why it matters
The commonest real-world refusal to register an FIR is not a refusal on the merits at all. It is the answer at the counter: this did not happen in our area, go to the other police station. A student who knows only that registration is compulsory still has to answer that objection, because the section itself speaks of the officer in charge of "a police station", and territorial limits are real.
Punati Ramulu removes the objection, and the Sanhita has now built the answer into the statute: BNSS s. 173(1) allows information relating to a cognizable offence to be recorded irrespective of the area where the offence is committed — the zero FIR, which until 2024 rested on decisions of this kind rather than on any section.
Facts
The case arose out of a refusal by a police officer to record information about a cognizable offence on the ground that the place of the crime did not fall within the territorial jurisdiction of his police station.
Held
The Court held that a refusal to record an FIR on the ground that the place of the crime does not fall within the territorial jurisdiction of the police station amounts to a dereliction of duty. Information about a cognizable offence has to be recorded and then forwarded to the police station having jurisdiction.
Reasoning
The duty and the venue are two different questions, and the decision keeps them apart. The duty to record is triggered by the character of the information — that it discloses a cognizable offence — and nothing in that trigger depends on where the offence occurred. Territorial jurisdiction governs which station must investigate, and that is answered by transmission of the recorded information, not by turning the informant away. Reading the two questions as one would make the informant bear the cost of the police force's internal division of labour, at the very moment when the record is most likely to be accurate.
Exam use
Use it in any question on refusal to register an FIR, and in any question on the zero FIR. It pairs with the rule that the police cannot refuse registration on the ground that the information is unreliable or not credible, and with the compulsory-registration rule in Lalita Kumari.
It disposes of the jurisdictional excuse. It does not decide that the receiving station must itself investigate — the whole point is that the recorded information is forwarded — and it does not touch the separate question of which court has jurisdiction to try the offence.
The decision was given on the 1973 Code. Cite it now as the authority behind BNSS s. 173(1), and say that what was a judicially imposed duty is, since 1 July 2024, written into the section.