As per the decision of the Supreme Court in Lalita Kumari v. Government of Uttar Pradesh, (2014) 2 SCC…

Lalita Kumari lists matrimonial or family disputes, commercial offences and medical negligence among illustrative categories where a preliminary inquiry may be appropriate. The inquiry is to ascertain whether a cognizable offence is disclosed, rather than to conduct a preliminary trial of truth. These categories do not displace mandatory FIR registration when the information already discloses a cognizable offence. Separately, section 173(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023 now permits a statutory preliminary enquiry, within fourteen days and with prior permission of an officer not below the rank of Deputy Superintendent of Police, for cognizable offences punishable with three years or more but less than seven years.