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Central Bureau of Investigation v. Thommandru Hannah Vijayalakshmi

Prevention of Corruption Act, 1988 – Whether a Preliminary Inquiry is mandatory before registering an FIR Held, In case the information received by the CBI, through a complaint or a “source information” under Chapter 8, discloses the commission of a cognizable offence, it can directly register a Regular Case instead of conducting a Preliminary Enquiry, where the officer is satisfied that the information discloses the commission of a cognizable offence.

Since the institution of a Preliminary Enquiry in cases of corruption is not made mandatory before the registration of an FIR under the CrPC, PC Act or even the CBI Manual, for this Court to issue a direction to that affect will be tantamount to stepping into the legislative domain. [Para 32]