Lalita Kumari v. Government of Uttar Pradesh (12 November 2013) addressed FIR registration and limited…

Section 173(3) allows a preliminary enquiry for a cognizable offence "punishable for three years or more but less than seven years", with "the prior permission from an officer not below the rank of Deputy Superintendent of Police", to be completed within fourteen days. Neither the station officer's nor a Magistrate's permission suffices. Lalita Kumari v. Government of Uttar Pradesh (2013) had required FIR registration where a cognizable offence is disclosed and allowed only a limited preliminary inquiry in some categories.