Karnataka High Court Quashes Cow Slaughter Case After Police Conduct Raid Before Registering FIR
Amruta Gangajaliwale
15 Oct 2026 2:59 PM IST
The Karnataka High Court has quashed criminal proceedings in a cow slaughter case, holding that the police violated the mandatory requirement of registering an FIR before conducting a raid and seizure after receiving information about a cognizable offence.Justice Rajesh Rai K held that the failure to register the FIR before undertaking substantial investigative steps, including searches,...
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The Karnataka High Court has quashed criminal proceedings in a cow slaughter case, holding that the police violated the mandatory requirement of registering an FIR before conducting a raid and seizure after receiving information about a cognizable offence.
Justice Rajesh Rai K held that the failure to register the FIR before undertaking substantial investigative steps, including searches, seizures and recording witness statements, vitiated the proceedings against the accused.
The case arose from a suo motu complaint lodged by a Police Inspector of Hunsur Town Police Station on February 26, 2023. Acting on information about the alleged illegal sale of beef without a licence or permission, the police conducted raids at several shops and godowns in Shabbeer Nagar.
During a raid on a godown allegedly linked to the petitioner, the police claimed to have found signs of cattle slaughter and seized a cattle carcass with two horns. Following the investigation, a charge sheet was filed, and the trial court took cognizance of offences under Section 429 of the Indian Penal Code (IPC) and provisions of the Karnataka Prevention of Slaughter and Preservation of Cattle Act, 2020.
The accused subsequently approached the High Court under Section 482 of the Code of Criminal Procedure (CrPC), seeking quashing of the criminal proceedings.
Referring to the Supreme Court's decision in Lalita Kumari v. State of Uttar Pradesh (2014), the High Court reiterated that registration of an FIR is mandatory upon receipt of information disclosing the commission of a cognizable offence, subject to the limited exceptions recognised by the Supreme Court.
The High Court observed that in the present case, police had received information regarding the alleged cognizable offence at around 9.30 a.m. on February 26, 2023. However, the information was registered in the Station House Diary much later, at 12 noon, after the raid and seizure of articles had already been conducted at the premises linked to the petitioner.
“The police, therefore, had sufficient opportunity to register the FIR before proceeding to conduct the raid. Despite the same, without registering the FIR and without even entering the information in the General Diary or Station House Diary, the police proceeded to conduct the raid and seizure. Only after conducting the raid, seizing the alleged meat and other articles and drawing the mahazars, the complaint came to be lodged and the FIR was registered,” the Court said.
The Court rejected the State's contention that the conduct of the police fell within the exception carved out by the Supreme Court in State of Jammu and Kashmir & others vs Dr. Saleem Ur Rahman (2022). In Dr. Saleem U Rahman case, the Apex Court had held that under the Prevention of Corruption Act, a preliminary inquiry to ascertain whether a prima facie case is made out does not automatically violate the principles laid down in Lalita Kumari.
Differentiating the present case from the 2022 Apex Court ruling, the High Court found that the police probe in the present case went beyond the ambit of a limited preliminary enquiry.
“The materials on record disclose that the police had already proceeded substantially with the investigation by conducting searches, effecting seizures and recording the statements of panch witnesses before registration of the FIR. Such acts cannot be treated as a limited preliminary inquiry of the nature contemplated in Dr. Saleem Ur Rahman supra,” the High Court observed.
Allowing the petition, the High Court held, “In view of the above discussion, I am of the considered view that the mandatory requirement under Section 154 of the Cr.P.C., as explained by the Hon'ble Apex Court in Lalita Kusmari supra, has not been complied with by the respondent-Police. The failure to register the FIR before proceeding with the raid and seizure, coupled with the fact that substantial investigative steps were undertaken prior to registration of the FIR, vitiates the proceedings initiated against the petitioner-accused.”
