This Judgment from Hon’ble Supreme Court talks about the importance of prompt lodging of the First Information Report and where not done so, the delay in lodging the complaint should be satisfactorily explained.
From Para 18,
Time and again, the object and importance of prompt lodging of the First Information Report has been highlighted. Delay in lodging the First Information Report, more often than not, results in embellishment and exaggeration, which is a creature of an afterthought. A delayed report not only gets bereft of the advantage of spontaneity, the danger of the introduction of coloured version, exaggerated account of the incident or a concocted story as a result of deliberations and consultations, also creeps in, casting a serious doubt on its veracity. Therefore, it is essential that the delay in lodging the report should be satisfactorily explained.
And… from Para 19,
State Of A.P vs M. Madhusudhan Rao on 24 October, 2008
No explanation worth the name for delay in filing the complaint with the police has come on record. We are of the opinion that this circumstance raises considerable doubt regarding the genuineness of the complaint and the veracity of the evidence of the complainant (PW-1) and her father (PW-3), rendering it unsafe to base the conviction of the respondent upon it. Resultantly, when the substratum of the evidence given by the complainant (PW-1) is found to be unreliable, the prosecution case has to be rejected in its entirety.
Other Source links: https://indiankanoon.org/doc/1273596/ or https://www.casemine.com/judgement/in/575fd30f607dba63d7e6b53e
Citation: [(2008) 15 SCC 582], [(2009) 3 SCC (Cri) 1123], [2008 (14) SCALE 118]
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