In Brief
The Supreme Court upheld an FIR against a public servant accused of acquiring assets disproportionate to his income under the Prevention of Corruption Act. The Court held that preliminary inquiry is not mandatory before FIR registration when detailed source information already discloses a cognizable offence. A comprehensive source information report can serve as substitute for preliminary inquiry. The Court further clarified that a Superintendent of Police can issue a composite order simultaneously directing FIR registration and authorizing investigation under Section 17 of the PC Act, without requiring a pre-existing formal FIR. This harmonizes the Prevention of Corruption Act with the Code of Criminal Procedure and prevents procedural barriers from impeding legitimate corruption investigations.
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