24/01/2026
1️⃣ FIR Lodged by the Aggrieved Person
Meaning:An FIR lodged directly by the victim or a person having direct knowledge of the offence.
Legal value:
✔ Strong evidentiary value
✔ Considered most reliable if lodged promptly
Case Law:
📌 Muhammad Akram v. State (2009 SCMR 230)
➡ Supreme Court held that FIR lodged by the aggrieved person at the earliest point of time carries great probative value.
2️⃣ FIR Lodged by an Eye-Witness
Meaning:
Filed by a person who personally saw the occurrence.
Legal value:
✔ Credible if the witness is trustworthy
✔ Delay must be reasonably explained
Case Law:
📌 Zulfiqar Ali v. State (2008 SCMR 492)
➡ FIR by an eye-witness is reliable if his presence at the scene is natural and confidence-inspiring.
3️⃣ FIR Lodged by a Stranger / Chance Witness
Meaning:
Filed by someone not related to the victim and not ordinarily present at the scene.
Legal value:
⚠ Requires careful scrutiny
⚠ Court examines reason for presence
Case Law:
📌 Abdul Khaliq v. State (2011 SCMR 554)
➡ FIR by a chance witness must be supported by independent corroboration.
4️⃣ FIR Lodged by Police (Suo Motu / On Information)
Meaning:
Police registers FIR on its own information (e.g., patrolling, wireless message, daily diary entry).
Legal value:
✔ Valid under Section 154 Cr.P.C.
⚠ Courts examine neutrality of police
Case Law:
📌 State v. Khadim Hussain (PLD 1976 SC 254)
➡ Police-initiated FIR is lawful but must be scrutinized with caution.
5️⃣ Delayed FIR
Meaning:
FIR lodged after an unexplained delay.
Legal value:
⚠ Delay creates suspicion of consultation or fabrication
✔ Delay is acceptable if properly explained
Case Law:
📌 Tariq Pervez v. State (1995 SCMR 1345)
➡ Delay in FIR is fatal unless satisfactorily explained.
6️⃣ Cross FIR
Meaning:
A counter version of the same incident filed by the opposite party.
Legal value:
✔ Both FIRs must be investigated impartially
✔ Neither version gets automatic preference
Case Law:
📌 Abdul Jabbar v. State (2010 SCMR 159)
➡ Cross FIRs should be decided on independent evaluation of evidence, not merely sequence.
7️⃣ False / Malafide FIR
Meaning:
An FIR lodged with ulterior motives such as enmity or pressure.
Legal consequence:
❌ Can be quashed
❌ Informant may face legal action
Case Law:
📌 Muhammad Bashir v. State (PLD 2007 SC 539)
➡ FIR lodged with malafide intent is an abuse of the process of law.
8️⃣ Supplementary Statement (Not a New FIR)
Meaning:
Additional facts added after FIR registration.
Legal position:
❌ Not treated as a second FIR
✔ Becomes part of investigation
Case Law:
📌 Riasat Ali v. State (PLD 2011 SC 218)
➡ Only one FIR is permissible; later versions are statements under Section 161 Cr.P.C.
