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to much more hazardous situation of people approaching the High Court seeking direction to police to register the Zero F.I.R. and then transfer the same to the concerned Police Station. This Court cannot be incognizant and oblivious of the said predicament while dealing with such speculative writ petitions.

22) As regards the concept of registration of "Zero F.I.R." is concerned, "Zero F.I.R." is an exception to the general rule of assigning number to the F.I.R. that is registered in a police station on the basis of the report that is lodged with the police. Therefore, a Zero F.I.R., as the name implies, is an F.I.R. without a serial number. A Zero F.I.R. would be registered in any police station where the information about a cognizable offence is received irrespective of whether it has territorial jurisdiction or not. Police can enquire or investigate the case on the basis of the Zero F.I.R. that is registered and if the police officer is of the opinion that the offence did not take place within the limits of his jurisdiction, he can send/transfer the F.I.R. to the appropriate police station, which got jurisdiction.

CMR,J.

and 'Zero FIR' is that an FIR is registered where the incident has occurred within the jurisdiction of a particular Police Station, and a zero FIR can be lodged at any Police Station irrespective of where the incident has taken place. A zero FIR is admittedly more efficient and is meant to provide quick redressal to the victim so that timely action can be taken after registration of the FIR. A glance through Circular 15/2019 by the Office of the Commissioner of Police, Delhi, dated 20.12.2019, issued in pursuance of instructions given by the Delhi High Court in Kirti Vashisht v. State of NCT of Delhi & Ors., [Writ Petition (Crl.) No. 5933/2019], also stipulates the directions that are to be followed with regard to a "Zero FIR".

involved in the said cases. While dealing with facts in the said cases, incidentally, it is held that police cannot refuse to register F.I.R. on the ground that it has no territorial jurisdiction as the offence took place outside the jurisdiction of the said police station and held that even in such cases, a Zero F.I.R. is to be registered and then to transfer the same to the concerned police station. Therefore, that is the only sublime essence or the ratio decidendi that is laid down in the said cases, which is almost akin to Lalita Kumari4 case. In Lalita Kumari4 case it is held that when a report is lodged with the police disclosing commission of a cognizable offence, it is mandatory on the police to register F.I.R. and to investigate the case. In the above judgments of the Delhi High Court and Karnataka High Court, it is held that even if a report is lodged disclosing commission of a cognizable offence, which took place outside the jurisdiction of the said Police Station, the police cannot refuse to register F.I.R. and still the police has to register a Zero F.I.R. and then transfer the F.I.R. to the concerned Police Station. That is the only difference between the two judgments. But, the principle is one and the same. In none of the said judgments, it is held that in case an F.I.R. is not registered or a Zero F.I.R. is not registered, in both the situations that the aggrieved person can approach the High Court under Article 226 of CMR,J.

the Constitution of India and seek a direction to register an F.I.R. or Zero F.I.R. No such law is laid down either in the Lalita Kumari4 case or in the aforesaid judgments of the Delhi High Court and the Karnataka High Court. Therefore, the petitioner cannot rely on those judgments and seek to maintain the present Writ Petition filed for a mandamus to direct the police to register an F.I.R. or a Zero F.I.R. So, the contention of the learned counsel for the petitioner that in view of the law laid down by the Apex Court in Lalita Kumari4 case, and in Umapathi S.13 case (of Karnataka High Court) and Neelu Shrivastava13 case (of Delhi High Court), that the writ for mandamus is maintainable and direction is to be given to the police to register the Zero F.I.R. is misconceived and unsustainable under law. The appropriate remedy is not the writ and the party has to avail the remedies contemplated under Cr.P.C. as discussed in detail supra, as per the settled law.