In a significant order delivered on February 19, 2026, the High Court of Karnataka set aside criminal proceedings against a Junior Wireless Officer, holding that the police could not register an FIR based on a second complaint when a Non-Cognizable Report (NCR) had already been filed earlier for the same incident.
Justice M.G. Uma allowed the petition filed under Section 482 of the Criminal Procedure Code (CrPC), observing that the registration of the FIR in such circumstances amounted to misuse of legal process .
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Background of the Case
The petitioner, Ramana Reddy G.V., was named as an accused in Crime No.181/2021 registered by Channammanakere Achu Kattu Police Station, Bengaluru. The allegations were under Sections 341 (wrongful restraint), 427 (mischief causing damage), 504 (intentional insult), and 506 (criminal intimidation) of the Indian Penal Code.
According to the complainant, who was his colleague, the officer entered her chamber shouting, allegedly lifted a chair and threatened her. She further claimed that he snatched her mobile phone and damaged it while she was recording the incident .
An NCR was registered on the basis of the first complaint dated February 3, 2021. However, several months later, on September 15, 2021, a fresh complaint was filed. Based on this second complaint, the police registered an FIR for the same set of allegations .
Arguments Before the Court
Counsel for the petitioner argued that once an NCR had been registered, the police could not simply register an FIR later on the basis of a nearly identical complaint, unless there were new facts or changed circumstances.
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The petitioner relied on earlier judgments, including the Supreme Court ruling in State of Haryana v. Bhajan Lal, to contend that such action fell within the category of cases where criminal proceedings deserve to be quashed.
On the other hand, the complainant’s counsel submitted that she had approached the National Commission for Women, and that the FIR was registered following communication from the Commission. However, the court noted that there was no material on record showing that the Commission had issued any direction to the police to register the FIR .
Court’s Observations
Justice Uma carefully examined the sequence of events. The court pointed out that when an NCR is registered, it means the alleged offences are treated as non-cognizable - in other words, the police cannot start a full investigation without following the procedure laid down under Section 155 of the CrPC.
“The Police Officer cannot proceed to register the FIR on the basis of a similar second complaint and proceed with the investigation without assigning any reason for such action,” the bench observed.
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The court also noted that the complainant had not followed the remedy available under Section 154(3) CrPC, which allows an informant to approach the Superintendent of Police if the officer-in-charge refuses to register an FIR .
Importantly, the judge found that the second complaint was “verbatim similar” to the first one, and there was no explanation as to why an FIR was suddenly registered months later when an NCR had already been issued.
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The Decision
Holding that the registration of the FIR ignored the earlier NCR and amounted to an abuse of process of law, the court allowed the criminal petition.
“The criminal proceedings initiated against the petitioner… are hereby quashed,” the order concluded .
With this, the proceedings in CC No.10494/2022 pending before the II Additional Chief Metropolitan Magistrate, Bengaluru, stood set aside.
Case Title: Ramana Reddy G V v. State of Karnataka & Anr.
Case No.: Criminal Petition No. 6805 of 2022
Decision Date: February 19, 2026
