2025 Supreme(Online)(AP) 14214

HIGH COURT OF ANDHRA PRADESH
N. HARINATH, J
DAYAM PEDA RANGA RAO – Appellant
Versus
THE JOINT DIRECTOR, (RAYALASEERNA) ANTI-CORRUPTION BUREAU, A.P – Respondent
CRIMINAL PETITION Nos.3955, 197, 433, 1376, 2211, 2253, 2451, 3808, 4308 and 4831 of 2021, 4469, 5844, 5958, 5985 of 2020 and 2066 of 2023 | CRLP.No. 3955/2021

An FIR registered by a non-notified police station under the Code of Criminal Procedure is void ab initio, and subsequent notifications do not retroactively validate earlier registrations.

Headnote:(A) Prevention of Corruption Act, 1988 - Sections 13(1)(e) and 13(2), Code of Criminal Procedure, 1973 - Section 2(s) - Quashing of FIRs - The petitioners challenged the registration of criminal cases by the Anti-Corruption Bureau on grounds of lack of authority as the Central Investigation Unit was not notified as a police station under the law - The court held that registration of FIRs by a non-notified police station is void ab initio and quashed the cases. (Paras 1-44)

(B) Criminal Procedure - Notifications - It was established that the notification of the CIU as a police station post-dated the registration of the FIRs, rendering the prior registrations unlawful. (Paras 33-44)

Facts of the case:
The petitioners contended that criminal cases against them for disproportionate assets were registered by the Anti-Corruption Bureau’s CIU, which was not a recognized police station under the applicable legal definitions at the time of registration. The petitioners argued that the FIRs were invalid leading to their wrongful implication. (Paras 1-19)

Findings of Court:
The Court found that since the necessary notifications had not been made before the registration of FIRs, all cases against the petitioners were quashed as they were void ab initio. (Paras 43-44)

Issues: The primary issues were whether the Central Investigation Unit was a proper police station for the purposes of registration of FIRs and the implications of the subsequent notification declaring it a police station. (Paras 1-12)

Ratio Decidendi: The court ruled that only those police stations duly notified can register FIRs as the definition provided under Section 2(s) of the Code of Criminal Procedure must be strictly adhered to; the notifications that came after the registration cannot retroactively validate those FIRs. (Paras 33-44)

Result: All crimes registered prior to the notification of CIU as a police station were quashed.