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Issues: Whether the Central Bureau of Investigation was bound to register a first information report and conduct a regular investigation on the basis of an anonymous complaint, and whether the writ court could direct investigation in the manner sought.
Analysis: The statutory scheme under the Delhi Special Police Establishment Act, 1946 empowered the Central Bureau of Investigation to act in accordance with law and its manual. A preliminary inquiry on an anonymous complaint was held to be permissible, and the mere receipt of such a complaint did not, by itself, require immediate registration of a first information report. The applicability of the Code of Criminal Procedure was recognized, but the facts did not make it obligatory to convert the preliminary inquiry into a regular case. The Court further held that a writ court ordinarily does not direct an investigative agency to investigate in a particular manner and may interfere only in exceptional cases, which were not made out here.
Conclusion: The request to compel registration of a regular case and to direct investigation in the manner prayed for was rejected, and the challenge to the dismissal of the writ petition failed. The direction to pay costs was set aside.
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