In which of the following cases the Supreme Court held that FIR was not substantive evidence and could…

Paragraph 26 of C. Magesh v State of Karnataka repeats that an FIR is not substantive evidence and cannot corroborate someone other than its maker. It can corroborate the informant's testimony. The quoted observation identifies this case; it should not be read to exclude legally permissible contradiction of the maker or another independently applicable evidentiary rule.

Current law: The FIR remains distinct from substantive proof of the offence under the new criminal-procedure and evidence statutes. BNSS 173 governs information in cognizable cases, while applicable evidentiary rules determine corroboration or contradiction. Pending CrPC proceedings continue under 531.