ANALYZING SECTION 154 CRPC + 173 OF BNSS IN LIGHT OF ZERO FIR: AN EMPIRICAL AND DOCTRINAL STUDY OF BNSS, 2023 IN LIGHT OF NCRB DATA
AUTHOR – MS. K. NOORUL SHIFA FARGATH*, MS. T. VAISHALI**, MR. S. SARAVANA KUMAR**
* STUDENT AT THE TAMIL NADU DR. AMBEDKAR LAW UNIVERSITY, SCHOOL OF EXCELLENCE IN LAW, CHENNAI, INDIA
** ASSISTANT PROFESSOR OF LAW, DEPARMTMENT OF CRIMINAL LAW AD CRIMINAL JUSTICE ADMINISTRATION, THE TAMIL NADU DR. AMBEDKAR LAW UNIVERSITY, SCHOOL OF EXCELLENCE IN LAW, CHENNAI, INDIA
BEST CITATION – MS. K. NOORUL SHIFA FARGATH, MS. T. VAISHALI, MR. S. SARAVANA KUMAR, ANALYZING SECTION 154 CRPC + 173 OF BNSS IN LIGHT OF ZERO FIR: AN EMPIRICAL AND DOCTRINAL STUDY OF BNSS, 2023 IN LIGHT OF NCRB DATA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 5 (12) OF 2025, PG. 690-698, APIS – 3920 – 0001 & ISSN – 2583-2344
ABSTRACT
The introduction of the Zero FIR mechanism under the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) represents a pivotal reform in India’s criminal justice system, ensuring that First Information Reports (FIRs) can be registered at any police station irrespective of territorial jurisdiction. This provision addresses longstanding procedural barriers that have historically delayed investigations and hindered victims’ access to justice. The doctrinal framework of FIRs, initially grounded in Section 154 of the Code of Criminal Procedure, 1973 (CrPC), has now been redefined under Section 173 of the BNSS, codifying judicial directions such as those laid down in Lalita Kumari v. Government of Uttar Pradesh which mandated compulsory FIR registration.[1]
Empirical data from the National Crime Records Bureau (NCRB) 2022 Report reveals persistent challenges in FIR registration and delays in investigation, particularly in cases involving sexual offences, cybercrimes, and inter-state crimes.[2]Zero FIR, by eliminating jurisdictional hurdles, directly responds to these concerns, reducing evidentiary loss and safeguarding victims’ rights.[3]However, its successful implementation depends on police accountability, adequate training, and robust technological infrastructure to prevent misuse and administrative lapses.
This paper undertakes a doctrinal and empirical analysis of Zero FIR under BNSS, drawing upon NCRB statistics, legislative developments, and judicial precedents. It argues that Zero FIR must be backed by uniform enforcement protocols, e-FIR mechanisms, and inter-jurisdictional cooperation to ensure its effective functioning. Ultimately, this study contends that the statutory recognition of Zero FIR strengthens India’s commitment to victim-centric justice, constitutional guarantees of fair trial, and timely access to justice.
Keywords – Zero FIR, Section 154 CrPC, Section 173 BNSS, 2023, FIR registration, NCRB crime data
[1] Lalita Kumari v. Gov’t of Uttar Pradesh, (2014) 2 SCC 1 (India).
[2] National Crime Records Bureau, Crime in India 2022: Statistics (Ministry of Home Affairs, Gov’t of India 2023), https://ncrb.gov.in.
[3] Ministry of Home Affairs, Bharatiya Nagarik Suraksha Sanhita, 2023 (No. 46 of 2023), Gazette of India, Dec. 25, 2023.