Commentary on the Supreme Court of India’s Judgment in AMIT KUMAR v. UNION OF INDIA (2025 INSC 384)

I. Introduction

The Supreme Court of India in AMIT KUMAR & ORS. v. UNION OF INDIA & ORS. (2025 INSC 384) delivered a landmark judgment regarding the mandatory registration of First Information Reports (FIRs) in cognizable offenses. The cross-appeals stemmed from two unfortunate incidents where students enrolled in the Indian Institute of Technology (IIT) Delhi were found dead in their hostel rooms under suspicious circumstances. When the families of these students reported their complaints disclosing potential cognizable offenses, the police only conducted inquest proceedings under Section 174 of the Code of Criminal Procedure (CrPC), without registering FIRs.

This judgment not only establishes the reinforced requirement that police officers must register FIRs when a complaint discloses a cognizable offense, but the Court also addresses the larger concern of student suicides in institutions of higher education. In a significant development, the Court establishes a National Task Force to investigate and tackle the mental health challenges faced by students, aiming to reduce the incidence of suicides and ensure a more supportive campus environment.

Key Issues Examined by the Court:

• Whether the police is justified in concluding a case solely based on inquest proceedings under Section 174 of CrPC without registering an FIR, even when the complaint discloses a cognizable offense.
• Whether allegations of abetment to suicide and caste-based discrimination trigger the mandatory registration of an FIR under Section 154 of the CrPC, especially where the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, may also be invoked.
• The need for an institutional mechanism/Task Force to address mental health issues and prevent suicides in higher educational institutions.

II. Summary of the Judgment

The Supreme Court held that the police must register an FIR whenever a complaint mentions facts that disclose a cognizable offense. Conducting a preliminary inquiry or limiting investigations to inquest proceedings (Section 174 of the CrPC) is not a lawful substitute for lodging an FIR under Section 154.

Specifically, the Court found that both families of the deceased students had lodged written complaints explicitly alleging foul play, caste-based discrimination, and abetment of suicide—cognizable offenses. The police, however, declined to register FIRs and instead relied on inquest proceedings to conclude that both students had died by suicide due to depression or academic failures. The Court emphasized that investigations under Section 174 of the CrPC are restricted to discovering apparent cause of death and cannot foreclose the possibility of cognizable offenses.

In a far-reaching order, the Court also constituted a “National Task Force” with membership drawn from legal, medical, sociological, and administrative domains. It entrusted the Task Force with inquiring into mental health conditions contributing to suicides in higher educational institutions, proposing reforms to combat issues like ragging, caste-based discrimination, and academic pressure. The Task Force must produce interim and final reports, which will enable comprehensive policymaking to avert further tragedies.

III. Analysis

A. Precedents Cited

The Court relied on a constellation of past rulings to bolster its conclusion:

• Lalita Kumari v. Government of U.P. (2014) 2 SCC 1: A Constitution Bench confirmed that the police must register an FIR when the information discloses a cognizable offense. No preliminary inquiry is generally permissible, barring certain exceptions.
• State Of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335): The Court held that the officer in charge of a police station cannot conduct an inquiry into the reliability or credibility of information before registering the FIR.
• Ashok Kumar Todi v. Kishwar Jahan (2011) 3 SCC 758: Clarified that the investigation commences only after the FIR is duly registered under Section 154 CrPC.
• Pedda Narayana v. State of Andhra Pradesh (1975) 4 SCC 153: Differentiated the limited scope of inquest proceedings (under Section 174 of CrPC) from a full investigation aimed at prosecuting offenses.

B. Legal Reasoning

1. Mandatory Nature of FIR Registration
   The Court stressed that once a complaint discloses recognizably cognizable offenses—such as abetment to suicide, caste-based atrocities, or other penal provisions—the police are duty-bound to register an FIR under Section 154 CrPC. Any prior inquiry to gauge “credibility,” “veracity,” or “authenticity” is impermissible outside certain narrowly defined exceptions.
2. Inquest Proceedings under Section 174 CrPC are Limited
   The bench highlighted that the purpose of an inquest is simply to determine whether the cause of death is accidental, suicidal, or homicidal. It does not replace a formal criminal investigation and cannot conclude culpability or lack thereof. Hence, closing the case solely based on a Section 174 inquest is unlawful if the complaint alleged a cognizable crime.
3. SC/ST Act and Prohibition on Preliminary Inquiry
   The Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, expressly forbids preliminary inquiry for registration of FIR (Section 18-A). Where an offense under the SC/ST Act is alleged, the police must register the FIR immediately.
4. Creation of a National Task Force on Student Suicides
   Recognizing multiple reported suicides among students in campuses such as IITs, NITs, IIMs, and other institutions, often triggered by stress, discrimination, or harassment, the Court instituted a National Task Force. Comprising eminent personalities including retired judges, psychiatrists, educationists, and civil rights activists, it has been charged with formulating recommendations and guidelines to prevent campus suicides and improve mental health support systems, as well as to address discrimination.

C. Impact of the Judgment

Immediate Consequences:

• The police in Delhi (specifically DCP, South-West District) is directed to register FIRs in the present matters, investigate them under relevant provisions of criminal law, and not limit themselves to inquest proceedings.
• All police stations subjected to the same principle: if a complaint discloses any cognizable offense, an FIR is to be registered without delay. This prevents “burking” of crime (i.e., suppressing complaints), ensuring accountability.

Long-Term Consequences:

• The newly constituted National Task Force can overhaul policies and frameworks in higher educational institutes to address mental health, academic pressure, and discriminatory practices. This can lead to uniform regulations, stronger counseling facilities, and enhanced monitoring of campus-related suicides.
• Universities and other institutions will be compelled to reevaluate safety protocols, counseling systems, and protective measures (including anti-ragging and anti-discriminatory practices) to ensure compliance with the guidelines likely to be framed by the Task Force.

IV. Complex Concepts Simplified

1. Section 174 CrPC (Inquest Proceedings)
   An inquest is meant to ascertain the cause of death and note any apparent injuries. It does not investigate who is responsible or whether a crime took place. Thus, it cannot replace a criminal investigation under a regular FIR if grave allegations exist.
2. Section 154 CrPC (Registration of FIR)
   As soon as the police receive information of a cognizable offense (for instance, allegations of murder, abetment to suicide, caste-based atrocities), they must record it in writing, known as the FIR. This step officially initiates the criminal investigation.
3. The SC/ST (Prevention of Atrocities) Act, 1989
   This special legislation criminalizes various forms of atrocities and discrimination against Scheduled Castes or Scheduled Tribes. It explicitly bars preliminary inquiries when an offense under the Act is alleged. Thus, if the complaint indicates caste-based discrimination or atrocity, registration of the FIR is mandatory.
4. National Task Force on Student Suicides
   The Court entrusts this multi-disciplinary body to diagnose reasons for the rise in student suicides in higher academia, propose institutional reforms, and ensure robust mental-health and anti-discriminatory support systems. It can conduct surprise inspections and gather data from institutions nationwide.

V. Conclusion

With this judgment, the Supreme Court reasserted the foundational principle that no police officer can bypass the mandate of Section 154 CrPC to register an FIR where a cognizable offense is disclosed. It denounced the practice of wholly relying on Section 174 inquest proceedings to “close” a potential criminal complaint.

By forming a National Task Force, the Court signals a systemic redressal approach, aiming to reduce student suicides through a strict review of mental health frameworks, anti-ragging measures, and anti-discrimination policies in campuses. The judgment inherently strengthens the rights of aggrieved families and reaffirms that educational institutions, as well as law enforcement, bear legal and moral responsibilities to safeguard every student’s life and well-being.

Ultimately, AMIT KUMAR v. UNION OF INDIA underscores that whenever any person approaches the police with a complaint that prima facie discloses a cognizable offense (especially under the SC/ST Act), the police cannot pre-emptively decide on the merits of the complaint. Instead, it must proceed with the legal formalities of registering an FIR and conducting an impartial, thorough investigation. Simultaneously, higher educational institutions are called upon to adopt heightened vigilance and stronger support structures for students—both academically and psychologically—to prevent further tragedies.