Investigation by FIR-recording officer is not barred absent specific facts showing bias or real likelihood of bias.

Sections 154, 156 and 157 of the CrPC permit a police officer in charge of a police station to record information about a cognizable offence and to investigate it. The mere fact that the same officer recorded the FIR on information received and later conducted the investigation does not, by itself, invalidate the inquiry or create a statutory bar. A challenge to such investigation requires specific facts showing bias or a real likelihood of bias; no absolute rule of disqualification applies. The Supreme Court distinguished the authorities relied on by the High Court and held that quashing the proceedings on this ground was erroneous.

---

---

Issues: Whether a police officer who records the first information report on the basis of information received is disqualified from investigating the cognizable offence and submitting the final report.

Analysis: Sections 154, 156 and 157 of the Code of Criminal Procedure, 1973 permit a police officer in charge of a police station to record information relating to a cognizable offence and to investigate such offence either on information or otherwise. The mere fact that the same officer recorded the FIR after receiving discreet information does not, by itself, create a statutory bar against investigation. Any challenge to such investigation must rest on specific facts showing bias or a real likelihood of bias; no broad rule can be laid down that investigation by the informant officer is necessarily unfair. The authorities relied upon by the High Court were distinguished on their facts and did not lay down an absolute prohibition.

Conclusion: The police officer was competent to investigate the case, and the High Court erred in quashing the proceedings on the ground that the FIR-recording officer had also conducted the investigation.

Ratio Decidendi: An investigation is not vitiated merely because the police officer who records the FIR on information received also conducts the investigation, unless specific circumstances establish bias or a real likelihood of bias.

---