Based on the provided legal document, here are the key points regarding the registration of counter-complaints (counter FIRs) under the Criminal Procedure Code, 1973:

• Counter-complaints are permissible: The registration of a complaint in the nature of a counter-case is not precluded from the purview of the Criminal Procedure Code, even if a prior FIR has been registered for the same incident. [IMPORTANT POINT]
• Distinction between successive FIRs and counter-complaints: While a second or successive FIR (not being a counter-case) filed regarding the same transaction where investigation is underway or a final report has been submitted may be quashed under Section 482 Cr.P.C. or Articles 226/227 of the Constitution, this prohibition does not apply to a counter-complaint alleging a different version of the incident by the accused. (!) (!) (!)
• Interpretation of T.T. Antony vs. State of Kerala: The Supreme Court clarified that its earlier judgment in T.T. Antony did not exclude the right to file a counter-complaint. The previous judgment only held that further complaints against the same accused by the same complainant (amounting to an improvement on facts) are prohibited under Section 162 Cr.P.C., but this does not bar a counter-complaint by the accused alleging a rival version. (!) (!) (!) (!)
• Role of Magistrate under Section 156(3): If the police refuse to register a counter-complaint, it is open to the Magistrate at any stage to direct the police to register the complaint and investigate it, exercising an independent power that does not conflict with other provisions. (!) (!)
• Irrelevance of Sections 161 and 162 Cr.P.C. to Registration: Sections 161 and 162 of the Code relate to the recording of statements during investigation and their evidentiary value, not to the registration of a criminal case. Therefore, they do not prohibit the registration of a counter-FIR. (!)
• Rival versions justify separate FIRs: In cases where there are rival versions regarding the same episode, it is legally permissible to register two different FIRs, and the investigation can be carried out under both by the same agency. (!)
• Prevention of false complaints: Allowing counter-complaints ensures that if a real accused lodges a false initial complaint, the aggrieved victim is not precluded from lodging their own complaint to bring the real culprit to book. (!)
• Further investigation permissible: Even after a prior complaint is registered and investigation initiated, a further complaint is permissible if it reveals a larger conspiracy or new discoveries, as held in Ram Lal Narang. (!) (!)
• Outcome in the present case: The Magistrate was justified in directing the police to register the appellant's complaint (Crime No. 48-A) under Sections 147, 148, 149, and 307 IPC, and the orders of the Sessions Judge and High Court setting aside this direction were set aside. (!) (!) (!)