Delhi High Court passed this order based on Lalita Kumari.

16. Learned APP has fairly conceded that as per the contents of the complaint, cognizable offence is made out. Thus, even on the first complaint made to Police Station, Najafgarh, the FIR was supposed to be registered. As per section 154 Cr.P.C., if any information relating to the commission of a cognizable offence is received by any Police Station, the said Police Station is duty bound to register the FIR. However, if the crime is not occurred in the jurisdiction of the said Police Station, then after registering the ‘Zero FIR’, the same has to be transferred to the concerned Police Station for investigation, where the offence has been committed. However, neither this happened in the Police Station Najafgarh nor thereafter in Police Station Baba Hari Das Nagar and also nor in Police Station Kapashera as well.
17. It is not in dispute that the provision of ‘Zero FIR‟ came up as a recommendation in the Justice Verma Committee Report, in the new Criminal Law (Amendment) Act, 2013 after the heinous ‘Nirbhaya Case’ of December, 2012. The provision says: “A Zero FIR can be filed in any police station by the victim, irrespective of their residence or the place of occurrence of crime.”
18. It is also not in dispute that the practice of ‘Zero FIR‟ is prevalent throughout India from the last many years. Thus, the Police Station of Kapashera, Najafgarh and Baba Hari Das Nagar were also aware about the said practice but none of the Police Stations till date have registered the case on the complaint of respondent no.7 whereas admittedly, cognizable offence has been committed as per the complaint of respondent no.7. Thus, the complainant/respondent no.7 was compelled to run from pillar to post due to inaction of the Police Stations mentioned above.